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Legislation
Income Tax Act 2007

Crossheading Transitional provision about protected foreign-source income and transitionally protected income

  • Section 735AA Settlements to which following sections apply
  • Section 735AB “Protected foreign-source income” and “transitionally protected income”
  • Section 735AC Transitionally protected income not to be taxed on remittance
  • Section 735AD Settlor liable for benefits charge despite being transferor
  • Section 735AE Settlor liable in place of close family member
  • Section 735AF Onward gifts from non-residents or qualifying new residents
  • Section 735AG Deduction allowed for previous settlements charge
  • Section 735B Historical liability under section 733A where remittance basis applied
  • Section 735C Historical operation of section 733C or 733E where remittance basis applied
  1. Transitional provision about protected foreign-source income and transitionally protected income
  2. Settlements to which following sections apply

Section 735AA | Settlements to which following sections apply

From legislation.gov.uk

(1)Sections 735AB to 735C apply if—

(a)a relevant transfer occurred before 6 April 2025,

(b)the person abroad was—

(i)the trustees of a settlement, or

(ii)a company in which the trustees of a settlement were participators or indirect participators, and

(c)protected foreign-source income or transitionally protected income arose in relation to the transfer.

(2)In sections 735AB to 735C—

“the relevant transfer” means the transfer referred to in subsection (1)(a);

“the settlement” means the settlement referred to in subsection (1)(b)(i) or (ii) (as the case may be);

“the settlor” means the settlor of that settlement.

(3)For the purposes of subsection (1)(b)(ii), the trustees of a settlement are “indirect participators” in a company if they are participators in the first in a chain of two or more companies where the last company in the chain is the person abroad and where each company in the chain (except the last) is a participator in the next company in the chain.

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