SCHEDULES

SCHEDULE 8Deemed domicile: income tax and capital gains tax

PART 2Protection of overseas trusts

ITTOIA 2005

24

1

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

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.