Part 9Special rules about settlements and trustees
Chapter 1Introduction
464Scottish trusts
1
This section applies if—
a
income arises to trustees under a trust having effect under the law of Scotland,
b
the trustees are UK resident, and
c
a beneficiary under the trust (“B”) would have an equitable right in possession to the income if the trust had effect under the law of England and Wales.
2
B is treated for income tax purposes as having an equitable right in possession to the income (even though B has no such right under the law of Scotland).