Part 2Income tax, corporation tax and capital gains tax
Chapter 4Trusts with vulnerable beneficiary
Capital gains tax
31UK resident vulnerable persons: F1amount of relief
(1)
Special capital gains tax treatment applies for the tax year in accordance with this section if the vulnerable person is UK resident F2for the tax year.
F3(2)
The trustees' liability to capital gains tax for the tax year is to be reduced by an amount equal to—
where—
TQTG is the amount of capital gains tax to which the trustees would (apart from this Chapter) be liable for the tax year in respect of the qualifying trust gains, and
VQTG is the amount arrived at under subsection (3).
(3)
That amount is—
where—
TLVB is the total amount of capital gains tax to which the vulnerable person is liable for the tax year, and
TL VA is what TLVB would be if the qualifying trust gains accrued to the vulnerable person (instead of to the trustees) and no allowable losses were deducted from the qualifying trust gains.