CG39110 | TCGA92/Sch4B - applies only to non-resident settlements

TCGA92/Sch4B/para3

TCGA92/Sch4B applies only to settlements within TCGA92/S86 and TCGA92/S87, TCGA92/Sch4B/para(1)(1)(a). The definition of whether a settlement is within section 86 or 87 is in TCGA92/Sch4B/para3.

For section 87 it includes settlements within TCGA92/S89(2), CG38600. These are settlements that were non-resident but have migrated to the UK with unmatched section 2(2)* amounts. TCGA92/S87 applies to match capital payments received when the settlement is UK resident to these unmatched trustee gains. In the unlikely event that a Schedule 4B gain accrued to such a settlement it would be taxed on the now UK resident trustees.

With this limited exception TCGA92/Sch4B applies only to non-resident settlements.

*This section was re-written for disposals from 6 April 2019 to section 1(3) see CG10150.