SCHEDULES

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

PART 2 U.K.Protection of overseas trusts

ITTOIA 2005U.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.