Attribution of gains to beneficiaries: cases involving transfers of value
143(1)Paragraph 12 (attribution of gains to settlor in section 10A cases) is amended as follows.
(2)For sub-paragraphs (1) to (3) substitute—
“(1)This paragraph applies if—
(a)by virtue of section 10A, an amount of chargeable gains within section 86(1)(e) that accrued in an intervening year to the trustees of a settlement would be treated as accruing to a person (“the settlor”) in the year of return, and
(b)after paragraph 8 has applied for the year of return, the section 2(2) amount for the intervening year that is in the Schedule 4C pool for the settlement is less than the amount mentioned in paragraph (a).
(2)The amount of chargeable gains treated as mentioned in sub-paragraph (1)(a) as accruing to the settlor in the year of return is limited to the section 2(2) amount referred to in sub-paragraph (1)(b).”