SCHEDULES

SCHEDULE 8 U.K. Deemed domicile: income tax and capital gains tax

PART 2 U.K. Protection of overseas trusts

ITTOIA 2005 U.K.

24 (1) Section 635 (capital sums treated under section 633 as income: meaning of “available income”) is amended as follows. U.K.

(2) In subsection (2), before “income” insert “ unprotected ”.

(3) After subsection (4) insert—

“(5) In subsection (2) “unprotected income” means income which is not protected foreign-source income, and sections 628A(2) to (13) and 628B (meaning of “protected foreign-source income”) have effect also for this purpose.”