20U.K.In section 87 (non-UK resident settlements: attribution of gains to beneficiaries), after subsection (5) insert—
“(5A)For the purpose of determining the section 2(2) amount for a settlement for a tax year—
(a)any chargeable gain or allowable loss accruing in that tax year on a non-resident CGT disposal made (or treated as made) by the trustees, other than an NRCGT gain chargeable to, or an NRCGT loss allowable for the purposes of, capital gains tax by virtue of section 14D, is to be treated as if it were a chargeable gain or (as the case requires) allowable loss falling to be taken into account in calculating the amount mentioned in subsection (4)(a), and
(b)such a disposal is otherwise to be disregarded.”