In paragraph 3 of Schedule 4B (transfers of value by trustees linked with trustee borrowing: settlements), for sub-paragraph (4) substitute—

“(4)

A settlement is “within section 87” for a tax year if—

(a)

section 87 applies to the settlement for that year, or

(b)

chargeable gains would be treated under section 89(2) as accruing in that year to a beneficiary who received a capital payment from the trustees of the settlement in that year.

(5)

The reference in subsection (4)(b) to chargeable gains treated as accruing includes offshore income gains treated as arising.”