SCHEDULES
SCHEDULE 8Deemed domicile: income tax and capital gains tax
PART 2Protection of overseas trusts
ITTOIA 2005
23
1
In section 629(5) (list of exceptions), at the end insert “or section 630A (exception for protected foreign-source income).
2
After section 630 insert—
630AException for protected foreign-source income
1
The rule in section 629(1) does not apply to income which arises under a settlement if it is protected foreign-source income for a tax year.
2
Sections 628A(2) to (12) and 628B (meaning of “protected foreign-source income”) have effect also for this purpose.
3
Section 648(3) to (5) (relevant foreign income treated as arising under settlement only if and when remitted) do not apply for the purposes of this section.