Income Tax Act 2007 (c. 3)

Part 9 U.K. Special rules about settlements and trustees

Chapter 10 U.K. Heritage maintenance settlements

Absence of election and income treated as income of settlor: special rules U.K.

511 Prevention of double taxation: reimbursement of settlor U.K.

(1) This section applies to income arising from heritage maintenance property if—

(a) the income is treated under Chapter 5 of Part 5 of ITTOIA 2005 as income of the settlor,

(b) the income is applied in reimbursing the settlor for expenditure incurred by the settlor for a property maintenance purpose, and

(c) the expenditure is deductible in calculating the profits of—

(i) a trade, or

(ii) a UK property business,

carried on by the settlor.

(2) Any such income—

(a) is not to be brought into account as a receipt in calculating the profits of that trade or business, and

(b) is not to be treated as income of the settlor otherwise than under Chapter 5 of Part 5 of ITTOIA 2005.