103U.K.In section 475 of ITA 2007 (residence of trustees), after subsection (6) insert—
“(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).”