Part 13Tax avoidance
Chapter 2Transfer of assets abroad
Transitional provision about protected foreign-source income and transitionally protected income
F1735BF2Historical liability under section 733A where remittance basis applied
F3(1)
This section applies in relation to income if—
(a)
the income was treated under section 732 as arising to an individual (“the beneficiary”) for any of the tax years 2017-18 to 2024-25,
(b)
the settlor was under section 733A(2) or (3) (as it had effect for that tax year) liable for tax on the income, and
(c)
section 809B, 809D or 809E (remittance basis) applied to the settlor for that year.
(2)
The income (“the transferred-liability deemed income”) is treated as relevant foreign income of the settlor.
(3)
If, for the purposes of section 735 as it applies in relation to the beneficiary, any benefit or relevant income relates to any part of the transferred-liability deemed income then, for the purposes of Chapter A1 of Part 14 as it applies in relation to the settlor, that benefit or relevant income is to be treated as deriving from that part of the transferred-liability deemed income.
(4)
In the application of section 832 of ITTOIA 2005 in relation to the income, subsection (2) of that section has effect with the omission of its paragraph (b).