Part 2Income tax, corporation tax and capital gains tax
Chapter 4Trusts with vulnerable beneficiary
Capital gains tax
32Non-UK resident vulnerable persons: amount of relief
1
Special capital gains tax treatment applies for the tax year in accordance with this section if the vulnerable person is non-UK resident during the tax year.
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 trusts gains, and
VQTG is an amount determined in accordance with section 33 (extra tax to which vulnerable person would be liable for the tax year if chargeable gains were treated as accruing to him under section 77(1) of TCGA 1992 by virtue of section 31 above).