After section 619 insert—

“619AIncome treated as highest part of settlor's total income

(1)

This section applies to income which is treated as income of a settlor as a result of section 624 (income where settlor retains an interest) or 629 (income paid to unmarried minor children of settlor).

(2)

The income is treated as the highest part of the settlor's total income for the purposes of section 619 (so far as it relates to the income).

(3)

See section 1012 of ITA 2007 (relationship between highest part rules) for the relationship between—

(a)

the rule in subsection (2), and

(b)

other rules requiring particular income to be treated as the highest part of a person's total income.”