(a) income which is treated as income of a settlor as a result of section 624 (income where settlor retains an interest),

(b) income which is treated as income of a settlor as a result of section 629 (income paid to unmarried minor children of settlor),

(c) capital sums which are treated as income of a settlor as a result of section 633 (capital sums paid to settlor by trustees of settlement), and

(d) capital sums which are treated as income of a settlor as a result of section 641 (capital sums paid to settlor by body connected with settlement).

(a) income chargeable under Chapter 3 of Part 4 (dividends etc. from UK resident companies etc.),

(b) income chargeable under Chapter 4 of Part 4 (dividends from non-UK resident companies),

(c) income chargeable under Chapter 5 of Part 4 (stock dividends from UK resident companies),

(d) income chargeable under Chapter 6 of Part 4 (release of loan to participator in close company), or

(e) a relevant foreign distribution chargeable under Chapter 8 of this Part (income not otherwise charged).

(a) is not chargeable under Chapter 4 of Part 4, but

(b) would be chargeable under Chapter 3 of that Part if the company were UK resident.

"settlement" includes any disposition, trust, covenant, agreement, arrangement or transfer of assets (except that it does not include a charitable loan arrangement), and

"settlor", in relation to a settlement, means any person by whom the settlement was made.

(a) has provided funds directly or indirectly for the purpose of the settlement,

(b) has undertaken to provide funds directly or indirectly for the purpose of the settlement, or

(c) has made a reciprocal arrangement with another person for the other person to make or enter into the settlement.

"charitable loan arrangement" means any arrangement so far as it consists of a loan of money made by an individual to a charity either-

(a) for no consideration, or

(b) for a consideration which consists only of interest, and

"charity" includes each of the bodies mentioned in section 507 of ICTA (the National Heritage Memorial Fund, the British Museum etc.).

(a) during the life of the settlor, and

(b) from property in which the settlor has an interest.

section 626 (exception for outright gifts between spouses),

section 627 (exceptions for certain types of income), and

section 628 (exception for gifts to charities).

(a) is payable to the settlor or the settlor's spouse,

(b) is applicable for the benefit of the settlor or the settlor's spouse, or

(c) will, or may, become so payable or applicable.

(a) the bankruptcy of a person who is, or may become, beneficially entitled to the property or any related property,

(b) the assignment of the property or any related property by such a person,

(c) the charging of (or, in Scotland, the granting of a right in security over) the property or any related property by such a person,

(d) in the case of a marriage settlement, the death of both parties to the marriage and of all or any of the children of the marriage, and

(e) the death of a child of the settlor who had become beneficially entitled to the property or any related property at not more than 25 years old.

(a) there are no circumstances in which the property or any related property can become payable or applicable as mentioned in that subsection during the life of a person other than-

(i) the bankruptcy of the person, or

(ii) the assignment or charging of the person's interest in the property or any related property, and

(b) the person is alive and under 25 years old.

(a) a spouse from whom the settlor is separated under an order of a court or a separation agreement,

(b) a spouse from whom the settlor is separated where the separation is likely to be permanent,

(c) the widow or widower of the settlor, or

(d) a person to whom the settlor is not married but may later marry.

(a) of property from which income arises,

(b) made by one spouse to the other, and

(c) meeting conditions A and B.

(a) it is subject to conditions, or

(b) there are any circumstances in which the property, or any related property-

(i) is payable to the giver,

(ii) is applicable for the benefit of the giver, or

(iii) will, or may become, so payable or applicable.

(a) arises under a settlement made by one party to a marriage by way of provision for the other-

(i) after the dissolution or annulment of the marriage, or

(ii) while they are separated under an order of a court, or under a separation agreement, or where the separation is likely to be permanent, and

(b) is payable to, or applicable for the benefit of, the other party.

(a) annual payments made by an individual for commercial reasons in connection with the individual's trade, profession or vocation,

(b) qualifying donations for the purposes of section 25 of FA 1990 (donations to charity by individuals), or

(c) a benefit under a relevant pension scheme.

(a) a registered pension scheme,

(b) a pension scheme established by a government outside the United Kingdom for the benefit, or primarily for the benefit, of its employees (or an annuity acquired using funds held for the purposes of such a pension scheme), or

(c) any pension arrangements of any description prescribed by regulations made under section 11(2)(h) of the Welfare Reform and Pensions Act 1999 (c. 30) or Article 12(2)(h) of the Welfare Reform and Pensions (Northern Ireland) Order 1999 (S.I. 1999/3147 (N.I. 11)).

(a) it is given by the trustees to a charity in the tax year in which it arises, or

(b) it is income to which a charity is entitled under the terms of the trust.

(a) income which is to be accumulated,

(b) income which is payable at the discretion of the trustees or any other person (whether or not the trustees have power to accumulate it), or

(c) income which (before being distributed) is income of any person other than the trustees.

(a) the amount of that income which falls within subsection (1), and

(b) the amount of that income which falls within section 630(1) (comparable exception for income of unmarried minor children of settlor).

"charity" includes each of the bodies mentioned in section 507 of ICTA (the National Heritage Memorial Fund, the British Museum etc.),

"resident", in relation to the trustees of a trust, is to be read in accordance with section 110 of FA 1989 (residence of trustees), and

"UK trust" means a trust whose trustees are UK resident.

(a) is paid to, or for the benefit of, an unmarried minor child of the settlor, or

(b) would otherwise be treated (apart from this section) as income of an unmarried minor child of the settlor.

(a) which is paid to or for the benefit of, or otherwise treated as income of, the child, and

(b) which (apart from subsection (3)) would be treated as income of the settlor under subsection (1).

section 631 for the treatment for the purposes of subsection (1) of retained or accumulated income, and

section 632 for the treatment for the purposes of this section and section 631 of certain deemed income connected to offshore income gains.
 

(a) "child" includes a stepchild,

(b) "minor" means a person under the age of 18 years, and "minor child" is to be read accordingly, and

(c) references to payments include payments in money's worth.

(a) it is given by the trustees to a charity in the tax year in which it arises, or

(b) it is income to which a charity is entitled under the terms of the trust.

(a) the amount of that income which falls within subsection (1), and

(b) the amount of that income which falls within section 628(1) (comparable exception for income where settlor retains an interest).

(a) the trustees of a settlement retain or accumulate income arising under the settlement, and

(b) a payment is subsequently made in connection with the settlement to, or for the benefit of, an unmarried child of the settlor.

(a) the settlement, or

(b) any enactment relating to the settlement.

A > B

where-

A is the total amount of the income which has arisen under the settlement since it was made, and

B is the total amount of disregarded income.
 

(a) treated as income of the settlor,

(b) paid (whether as income or capital) to, or for the benefit of, a beneficiary other than an unmarried minor child of the settlor,

(c) otherwise treated as the income of such a beneficiary,

(d) treated as income of an unmarried minor child of the settlor, and subject to income tax, in any of the tax years 1995-96, 1996-97 and 1997-98, or

(e) applied in meeting expenses of the trustees which-

(i) were properly chargeable to income, or

(ii) would have been so chargeable but for any express provisions of the trust.

TI > TAD

where-

TI is the child's total income for income tax purposes, and

TAD is the total amount of allowances and deductions that may be set against the total income.
 

(a) an offshore income gain accrues in respect of a disposal by a trustee of assets held by the trustee for a minor, and

(b) the minor would be absolutely entitled as against the trustee but for being a minor.

(a) is not treated under subsection (2) as the settlor's income for the tax year in which it is paid, and

(b) falls within the amount of the income available up to the end of the following year.

section 634 (meaning of "capital sum" and "sums paid to settlor"),

section 635 (amount of available income),

section 636 (calculation of undistributed income), and

section 637 (qualifications to section 636).

section 638 (capital sums paid by way of loan or repayment of loan),

section 639 (loans to participators in close companies), and

section 640 (grossing-up of deemed income).

(a) any sum paid by way of loan or repayment of a loan, and

(b) any other sum which-

(i) is paid otherwise than as income, and

(ii) is not paid for full consideration in money or money's worth.

(a) in one of the circumstances mentioned in subsection (2) of section 625, or

(b) on the death under the age of 25 of any person of the kind mentioned in subsection (3) of that section.

(a) is paid by the trustees of a settlement to a third party-

(i) at the settlor's direction, or

(ii) as a result of the assignment by the settlor of the settlor's right to receive the sum, or

(b) is otherwise paid, or applied by, the trustees for the benefit of the settlor,

(a) the spouse of the settlor, or

(b) the settlor (or the spouse of the settlor) jointly with another person.

(a) the amount of that income taken into account under section 633 in relation to that sum in any previous year or years,

(b) the amount of that income taken into account under section 633 in relation to any other capital sums paid to the settlor in any year before that sum was paid,

(c) any income arising under the settlement in that year or any previous year which has been treated as income of the settlor under section 624 or 629, and

(d) an amount equal to the sum of tax at the rate applicable to trusts on-

(i) the total amount of income arising under the settlement in that year and any previous year which has not been distributed, less

(ii) any income of the kind mentioned in paragraph (c).

(a) the sums to which subsection (2) applies,

(b) the expenses to which subsection (4) applies, and

(c) if the trustees of the settlement are trustees for charitable purposes, the amount to which subsection (6) applies.

(a) are treated in that year (otherwise than under section 633) as the income of those persons for income tax purposes, or

(b) would be so treated if those persons were domiciled, resident and ordinarily resident in the United Kingdom and the sums had been paid to them there.

(a) does not apply to expenses so far as they are included in the sums mentioned in subsection (2), and

(b) is subject to section 637(2) to (7).

A > B

where-

A is any income arising under the settlement in the tax year in respect of which exemption from tax may be granted under section 505 of ICTA (charities: general), and

B is the total amount of any such sums or expenses as are mentioned in subsections (2) and (4) paid in that year which are properly chargeable to the income.
 

(a) to any interest paid by the trustees of the settlement, or

(b) to any sums paid to-

(i) a body corporate connected with the settlement, or

(ii) the trustees of another settlement made by the settlor or by the trustees of the settlement.

where-

A is the whole of the income arising under the settlement in the tax year, less the sums referred to in subsection (4) of section 636 apart from subsections (2), (3) and (6) of this section, and

B is so much of the sums within subsection (2) of that section as is paid to persons other than the settlor or the spouse of the settlor.
 

(a) interest in respect of which relief from tax is allowable under any provision of the Income Tax Acts, or

(b) interest payable to the settlor or the spouse of the settlor if living with the settlor.

(a) it is a close company (or only is not a close company because it is non-UK resident) and the participators then include the trustees of the settlement, or

(b) it is controlled by a company falling within paragraph (a).

(a) a capital sum is paid to the settlor by way of loan, and

(b) one or more capital sums have previously been paid to the settlor by way of loan and wholly repaid.

(a) a capital sum is paid to the settlor by way of complete repayment of a loan, and

(b) an amount not less than the capital sum is subsequently lent by the settlor to the trustees of the settlement.

(a) tax at the rate applicable to trusts for the year on the amount treated under section 633 as the settlor's income,

(b) so much of the amount of tax at that rate as is equal to the tax charged, or

(c) the amount of tax paid by the trustees on the grossed-up amount of so much of the amount of income available up to the end of the year, in relation to the capital sum, as is taken into account under section 633 in relation to that sum in that year (see subsections (4) to (7) below),

(a) any reduction falling to be made under section 635(3)(d) is treated as made against income arising under the settlement in an earlier tax year before income arising under the settlement in a later tax year, and

(b) income arising under the settlement in an earlier tax year is treated as taken into account under section 633 before income arising under the settlement in a later tax year.

(a) the grossed-up amount of any sum is an amount equal to the sum, grossed up by reference to the appropriate rate for each part of the sum, and

(b) the amount of tax paid by the trustees on that grossed-up amount is the difference between the grossed-up amount and the sum in question.

(a) the appropriate rate for any part of a sum is 0% if-

(i) the income that falls to be treated in accordance with subsection (4) as representing that part of the sum is income from a source outside the United Kingdom, and

(ii) the trustees were non-UK resident for the relevant tax year, and

(b) the appropriate rate for any part of a sum in relation to which paragraph (a) does not apply is-

(i) 34%, if the relevant tax year is the year 2003-04 or any earlier tax year, and

(ii) 40%, if the relevant tax year is the year 2004-05 or any subsequent tax year.

(a) a capital sum is paid to the settlor in a tax year by any body corporate connected with the settlement in that year, and

(b) an associated payment has been, or is, made directly or indirectly to the body by the trustees of the settlement.

(a) is not treated as paid to the settlor in the year mentioned in subsection (3), and

(b) falls within the total of the associated payment or payments made up to the end of the following year (less what was taken into account under subsection (3) in relation to the sum in the previous year).

(a) the references to the following year are to the subsequent year,

(b) the reference to the year mentioned in subsection (3) is to that year and any other year before the subsequent year, and

(c) the reference to what was taken into account under subsection (3) in relation to the sum in the previous year is to what was taken into account under this section in relation to the sum in the previous years.

section 642 (exception for certain loans or repayments of loans), and

section 643 (interpretation of sections 641 and 642).

(a) to the settlor by the body corporate connected with the settlement or by any other body corporate so connected, or

(b) by the settlor to the body corporate connected with the settlement or to any other body corporate so connected.

(a) to the settlor by a body corporate, or

(b) to a body corporate by the trustees,

(a) any capital sum paid to the body by the trustees of the settlement, and

(b) any other sum paid, or asset transferred, to the body by the trustees which is not paid or transferred for full consideration in money or money's worth,

(a) references to the property comprised in a settlement include only property originating from the settlor, and

(b) references to income arising under the settlement include only income originating from the settlor.

(a) income originating from the settlor, and

(b) in a case in which section 631 applies, payments which under that section (as adapted by subsection (5) below) are treated as payments of income.

(a) the reference to income arising under the settlement includes only income originating from the settlor, and

(b) the reference to any payment made in connection with the settlement includes only a payment made out of property originating from the settlor or income originating from the settlor.

(a) property which the settlor has provided directly or indirectly for the purposes of the settlement,

(b) property representing property so provided, and

(c) so much of any property which represents both property so provided and other property as, on a just and reasonable apportionment, represents the property so provided.

(a) income from property originating from the settlor, and

(b) income provided directly or indirectly by the settlor.

(a) include references to property or income which has been provided directly or indirectly by another person under reciprocal arrangements with the settlor, but

(b) do not include references to property or income which the settlor has provided directly or indirectly under reciprocal arrangements with another person.

(a) any trustee, or

(b) any other person to whom the income is payable in connection with the settlement,

(a) the amount of income in respect of which the settlor has so paid tax, and

(b) the amount of tax so paid.

(a) a settlor obtains a repayment of tax in respect of an allowance or relief, and

(b) the repayment is in excess of the amount of the repayment to which the settlor would have been entitled but for sections 624 to 632.

(a) the trustee, or

(b) the other person to whom the income is payable by virtue of or as a result of the settlement.

(a) the amount of a payment under subsection (5), or

(b) an apportionment to be made under subsection (6),

(a) any income chargeable to income tax by deduction or otherwise, and

(b) any income which would have been so chargeable if it had been received in the United Kingdom by a person domiciled, resident and ordinarily resident there.

(a) not domiciled in the United Kingdom,

(b) not UK resident, or

(c) not ordinarily UK resident.