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SCHEDULES

SCHEDULE 10U.K.Settlements: anti-avoidance etc

PART 2 U.K.Income tax

ITTOIA 2005U.K.

10U.K.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.