TTM12060 | Tonnage tax groups: Control

Meaning of 'settlement' and 'settlor'

‘Settlement’ includes any disposition, trust, covenant, agreement, arrangement or transfer of assets.

‘Settlor’ in relation to a settlement, means any person by whom the settlement was made.

See FA00/SCH22/PARA144 (3) and ITTOIA05/S620 (1).

A person shall be deemed to have made a settlement if:

• he has made or entered into the settlement directly or indirectly, or

• he has provided or undertaken to provide funds directly or indirectly for the purposes of the settlement, or

• he has made with any other person a reciprocal arrangement for that other person to make or enter into the settlement.

References