Part 9Special rules about settlements and trustees

Chapter 10Heritage maintenance settlements

Absence of election and income treated as income of settlor: special rules

511Prevention of double taxation: reimbursement of settlor

(1)

This section applies to income arising from heritage maintenance property if—

(a)

the income is treated under Chapter 5 of Part 5 of ITTOIA 2005 as income of the settlor,

(b)

the income is applied in reimbursing the settlor for expenditure incurred by the settlor for a property maintenance purpose, and

(c)

the expenditure is deductible in calculating the profits of—

(i)

a trade, or

(ii)

a UK property business,

carried on by the settlor.

(2)

Any such income—

(a)

is not to be brought into account as a receipt in calculating the profits of that trade or business, and

(b)

is not to be treated as income of the settlor otherwise than under Chapter 5 of Part 5 of ITTOIA 2005.