Part 9Special rules about settlements and trustees
Chapter 1Introduction
464Scottish trusts
(1)
This section applies if—
(a)
income arises to trustees under a trust having effect under the law of Scotland,
(b)
the trustees are UK resident, and
(c)
a beneficiary under the trust (“B”) would have an equitable right in possession to the income if the trust had effect under the law of England and Wales.
(2)
B is treated for income tax purposes as having an equitable right in possession to the income (even though B has no such right under the law of Scotland).