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Income Tax (Trading and Other Income) Act 2005

Section 715: Interest from FOTRA securities held on trust

2739.This section reflects an Inland Revenue practice to regard the interest from a FOTRA security held in trust as exempt (and the beneficial ownership test in the exemption condition as satisfied) where none of the beneficiaries of the trust is ordinarily resident in the United Kingdom at the time when the interest arises. See Change 116 in Annex 1. It is new. The section refers to “interest” and not “profits” because this reflects the Inland Revenue practice. It is not likely that trading profits or any other kind of income (apart from interest) could arise in respect of FOTRA securities held in trust.

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