7

Subsection (8) applies if—

a

an individual becomes or ceases to be a trustee of the settlement during a tax year,

b

that year is a split year as respects the individual, and

c

the only period in that year when the individual is a trustee of the settlement falls wholly within the overseas part of the year.

8

The individual is to be treated for the purposes of subsections (4) and (5) as if he or she had been non-UK resident for the year (and hence for the period in that year when he or she was a trustee of the settlement).

9

But subsection (8) is subject to subsection (6) and, accordingly, an individual who is treated under subsection (8) as having been non-UK resident is, in spite of that, to be treated as UK resident whenever the individual acts as mentioned in subsection (6).