SCHEDULES
SCHEDULE 10Settlements: anti-avoidance etc
PART 2Income tax
ITTOIA 2005
10
In section 637 (qualifications to section 636)—
a
in subsections (2), (3) and (4) (extent to which interest treated as deductible trust expenses), before “interest” insert “
relevant
”
,
b
in subsection (5) (the relevant fraction), in the definition of “A”, before “income” insert “
unprotected
”
, and
c
after subsection (7) insert—
7A
In this section “relevant interest” means interest which, in the absence of any express provision of the settlement, would be properly chargeable to unprotected income.