16 - Income Tax
16 - Income Tax
Total income
- It comprises of the following viz. -
- Non-savings income
- Savings income
- Dividend income
Non-savings income
- It comprises of the following viz. -
- Employment income
- Property income
- Investment income
- Trading income
- Other taxable incomes
Savings income
- It comprises of interest income
- It is taxed at the same rates as the non-savings income but due to savings starting rate
band and savings nil rate band it is shown separately
Dividend income
- It comprises of dividend income
It is taxed at different rates from the non-savings income and thus it is shown
-
separately
Dividend nil rate band
- It will be available when the individual is having dividend income
Losses
- It comprises of the following viz. -
-
-
-
-
-
Personal allowance
- It is that portion of net income which is tax-free
It will be subtracted from the non-savings, savings and dividend income in such
-
manner
which is most beneficial for the individual
Notes -
- It will be available to all the UK resident individuals (including children)
- It will be available in full in the year of birth and in the year of death
Exempt income
- It comprises of the following viz. -
- Interest income from income tax refund
- Interest income from national savings certificate
- Interest income from damages for personal injuries
- State benefits
- Scholarships and grants
- Winnings from betting, gambling, gaming, lottery or races
- HMRC's contribution into the personal pension scheme
- Any withdrawals from the pension scheme upto the specified limits
- Any income from investments held in individual's savings account
- Any income from investments held in venture capital trust scheme
- Any income from investments held in enterprise investment scheme
- Any income from investments held in seed enterprise investment scheme
Chapter 02 - Computation of income tax payable by the individuals
Proforma - Income tax payable Amount
Income tax xx
Less: Other reliefs xx
Income tax liability xxx
Less: Tax credits xx
Income tax payable xxxx
Income tax
- It is paid by any chargeable individual on the basis of the following viz. -
- The taxable income earned or received by them during the tax year
- The income tax bands under which they are falling
Chargeable individual
- It means any individual whether UK domiciled or not-UK domiciled
- UK resident individuals will pay income tax on their worldwide incomes
- Non-UK resident individuals will pay income tax only on their UK based incomes
Taxable income
- It is that portion of net income which is taxable
Tax year
- It starts from 06th April, 202X and it ends on 05th April, 202Y
Other reliefs
- It comprises of the following viz. -
- Interest paid (including bank charges) on loan taken irt any residential property - 20%
- Investments held in individual's savings account - 00%
- Investments held in venture capital trust scheme - 30%
- Investments held in enterprise investment scheme - 30%
- Investments held in seed enterprise investment scheme - 50%
- Double taxation relief
Tax credits
- It comprises of the following viz. -
- Marriage allowance - 20%
- Non-savings income from real estate investment trust - 20%
- Savings income from real estate investment trust - 00%
- Dividend income from real estate investment trust - 8.75%
- Non-savings income from interest in possession trust - 20%
- Savings income from interest in possession trust - 20%
- Dividend income from interest in possession trust - 8.75%
- Non-savings income from discretionary trust - 45%
- Savings income from discretionary trust - 00%
- Dividend income from discretionary trust - 00%
- Non-savings income from disabled trust - 20%
- Savings income from disabled trust - 20%
- Dividend income from disabled trust - 8.75%
- Pay as you earn
Chapter 03 - Taxation of family members and connected persons
Family members
- It comprises of the following viz. -
- Grandparent
- Parent
- Spouse
- Brother and their spouse
- Sister and their spouse
- Children and their spouse
- Grandchildren and their spouse
Notes -
- It includes the following viz. -
- In-laws
- Step family
- It does not include the following viz. -
- Granduncle and their spouse
- Grandaunt and their spouse
- Uncle and their spouse
- Aunt and their spouse
- Cousin and their spouse
- Nephew and their spouse
- Niece and their spouse
- Grandnephew and their spouse
- Grandniece and their spouse
Connected persons
- It comprises of the following viz. -
- Friends and their family
- Partners and their family
- Trustees and their family
-
-
Notes -
- Any other person will be considered as unconnected person
-
-
-
-
Marriage allowance
- It is available when both the spouses are basic rate taxpayer
- Any spouse can transfer their personal allowance as marriage allowance to the other
spouse
Notes -
- It will be available in full in the year of marriage, in the year of separation and in the
year of death of first spouse
Personal allowance
- The personal allowance of the transferor spouse will be reduced
- The personal allowance that can be transferred will be equal to 10% of the available
personal allowance and it cannot change
- If the personal allowance of the transferor spouse is less than the personal allowance
that can be transferred then they will transfer the full amount and they will pay income
tax on the difference
Tax credits
- The tax credits of the transferee spouse will be increased
- The tax credits that can be received will be equal to 20% of the personal allowance
that can be transferred and it cannot change
- If the income tax liability of the transferee spouse is less than the tax credits that
can be received then they cannot claim income tax refund and their balance amount
will lapse
Children
- Each child will file their separate income tax return
Any income from parental disposition
- If any child derives any income from such sources which are set-up through parental
disposition then such income will be taxed in the hands of their parent unless -
- Such income is ≤ £100
- Such child is under 18 years (and unmarried)
Connected persons
- They will file their separate income tax return
Arm's length transaction
- It will be considered to be taken place at the actual value on the date of transaction
Unconnected persons
- They will file their separate income tax return
Employment income
- It is assessed on receipt basis
Employment status
- It can be found in the contract which the individual is holding with their employer
- If it cannot be found in the contract or if there is no contract in place then the HMRC
have laid down certain factors which can be used for finding out the employment status
of the individual
Factors Description
Obligated The individual must be obligated to perform the given work
Control The individual must not have control over the work performed
Fixed hours The individual must be committed to the work for fixed number of hours
Integral part The individual must perform such work which is integral part of the business
Risk The individual must not fear the risk of not being paid regularly or on-time
Equipment The individual must be provided with the equipment for performing the work
Right If any individual is having any right under any legislation or otherwise to be
treated as an employee then that individual is an employee
Salary income
- It comprises of the following viz. -
- Basic salary
- Bonus and commission
- Payments in-lieu-of notice
- Employer's contribution into the national insurance contribution
- Tax advantage share option schemes and share incentive plans
- Non-tax advantage share option schemes and share incentive plans
- Post-employment notice payments above £30000 less statutory redundancy payments
(if any)
- Non-contractual or ex-gratia payments above £30000 less statutory redundancy
payments (if any)
Employment benefits
It comprises of any benefit given directly or indirectly to the employee or their
-
family
member by the employer or any third party
Car benefit
- It arises when any car is given for personal use
- Taxable benefit = List price x Benefit percentage x Number of months used during the
tax year ÷ 12
- Any amount reimbursed by the employee being -
- Regular payment will be reduced from the taxable benefit
- One-time payment will be reduced from the list price (maximum £5000)
- The taxable benefit will not be increased by any expense incurred on running and
maintaining the car
- The taxable benefit will be increased by any expense incurred on providing driver
or chauffer with the car (full expense)
- The taxable benefit will be decreased if the car is not available for continuous use
of 30 days or more
Van benefit
- It arises when any van is given for personal use
- Taxable benefit = £3600 x Number of months used during the tax year ÷ 12
- Any amount reimbursed by the employee being regular payment will be reduced from
the taxable benefit
- The taxable benefit will not be increased by any expense incurred on running and
maintaining the van
- The taxable benefit will be increased by any expense incurred on providing driver
or chauffer with the van (full expense)
- The taxable benefit will be decreased if the van is not available for continuous use
of 30 days or more
Pool car fuel benefit
- It arises when any pool car fuel is provided
- Taxable benefit = Nil
Car fuel benefit
- It arises when any car fuel is given for personal use
- Taxable benefit = £25300 x Benefit percentage x Number of months used during the
tax year ÷ 12
- If partial amount is reimbursed by the employee then it will be ignored
- If full amount is reimbursed by the employee then it will be reduced from the taxable
benefit
Additional owned living accommodation benefit (accommodation costing > £75000 owned for
≤ 6 years)
- It arises when any accommodation costing > £75000 owned for ≤ 6 years is given to
live-in
- Taxable benefit = 02% x (Cost of acquisition, enhancement and improvement (including
incidental costs) incurred till the start of the tax year - 75000)
Additional owned living accommodation benefit (accommodation costing > £75000 owned for
> 6 years)
- It arises when any accommodation costing > £75000 owned for > 6 years is given to
live-in
- Taxable benefit = 02% x (Market value on the date when the accommodation was given
to live-in for the first time - 75000)
Loan benefit
- It arises when any loan of ≥ £10000 in aggregate is given at such rate which is less
than the official rate of interest
- Taxable benefit (average method) = (02% x (Loan o/s at the start of the tax year
+ Loan o/s at the end of the tax year) ÷ 2) - Interest paid during the tax year
- Taxable benefit (precise method) = (02% x Daily, monthly or quarterly loan o/s)
- Interest paid during the tax year
- Taxable benefit will be NIL in the following cases viz. -
- If the loan is provided for any qualifying purpose
Scholarship benefit
- It arises when any scholarship is given
- Taxable benefit = Actual amount of scholarship given
- Taxable benefit will be NIL in the following cases viz. -
- If the scholarship is provided through any trust
- If the scholarship is provided to any family member who is in any school, college or
university
Travelling expense
- It is available irt any expense incurred by the employee for travelling to and from
any temporary place of business
- Allowable deduction = Any expense incurred by the employee
- Reimbursed expenses = Any amount reimbursed by the employer
- Temporary place of business means any place of business where the employee will not
work continuously for > 24 months
Mileage allowance
- It is available irt any expense incurred by the employee for travelling to and from
any place of business on their personal vehicle
- Allowable deduction = As per the approved rates
- Reimbursed expenses = Any amount reimbursed by the employer
Employee's contribution into the share option schemes and share incentive plans
- It is available irt any contribution made by the employee into the share option schemes
and share incentive plans
- Allowable deduction = Any expense incurred by the employee
- Reimbursed expenses = Any amount reimbursed by the employer
Subscription or membership fees paid to any professional body
- It is available irt any subscription or membership fees paid to any professional body
- Allowable deduction = Any expense incurred by the employee
- Reimbursed expenses = Any amount reimbursed by the employer
Cost of acquisition, enhancement and improvement (including incidental expenses) irt any
asset purchased by the employee to be used for performing their duties
- It is available irt cost of acquisition, enhancement and improvement (including incidental
expenses) irt any asset purchased by the employee to be used for performing their
duties
- Allowable deduction = NIL
- Reimbursed expenses = Any amount reimbursed by the employer
Capital allowances irt any asset purchased by the employee to be used for performing their
duties
- It is available irt capital allowances irt any asset purchased by the employee to be used
for performing their duties
- Allowable deduction = Any expense incurred by the employee
- Reimbursed expenses = Any amount reimbursed by the employer
Expense incurred on repairing and maintaining irt any asset purchased by the employee
to be used for performing their duties
- It is available irt any expense incurred on repairing and maintaining irt any asset
purchased by the employee to be used for performing their duties
- Allowable deduction = NIL
- Reimbursed expenses = Any amount reimbursed by the employer
Interest paid (including bank charges) on loan taken irt any asset purchased by the employee
to be used for performing their duties
- It is available irt any interest paid (including bank charges) on loan taken irt any asset
purchased by the employee to be used for performing their duties
- Allowable deduction = Any expense incurred by the employee
- Reimbursed expenses = Any amount reimbursed by the employer
Interest paid (including bank charges) on loan taken irt any plant and machinery purchased
by the employee to be used for performing their duties
- It is available irt any interest paid (including bank charges) on loan taken irt any plant
and machinery purchased by the employee to be used for performing their duties
- Allowable deduction = NIL
- Reimbursed expenses = Any amount reimbursed by the employer
Exempt income
- It comprises of the following viz. -
- Car parking and charging facilities
- Canteen facilities
- Nursery facilities
- Sports and recreational facilities
- Welfare counselling facilities
- Cash vouchers
- Cost of uniform
- Cost of one mobile phone
- Mobile bills of one mobile phone
- Gifts from the employer upto £50
- Gifts from third party upto £250
- Staff parties upto £150
- Tax planning advice upto £500
- Medical treatments upto £500
- Transportation services
- Security services
- Training services
- Re-allocation expenses upto £8000
- Overnight stay expenses upto £5 per night in the UK
- Overnight stay expenses upto £10 per night in overseas
- Home worker expenses upto £6 per week or £26 per month
- Long service award upto £50 for each completed year
- Health insurance, life insurance, liability insurance premiums etc.
- Employment benefits given to the employee for performing their duties
- Employer's contribution into the occupational pension scheme
- Employer's contribution into the share option schemes and share incentive plans
- Interest income from share option schemes and share incentive plans
- Dividend income from share option schemes and share incentive plans
- Lumpsum payments on termination due to illness, injury, disability or death
- Retirement benefits
- Statutory redundancy payments
- Post-employment notice payments upto £30000 less statutory redundancy payments
(if any)
- Non-contractual or ex-gratia payments upto £30000 less statutory redundancy
payments (if any)
Chapter 06 - Pension schemes
Pension schemes
- It is an arrangement where any individual can invest in such schemes which encourages
them to save for their retirement
Enrolment
Any individual who is employed in the UK will be enrolled into this scheme
-
automatically
- Any individual can opt-out of this scheme at anytime
Contributions
- Any contribution into this scheme will be made in gross i.e. 100% will be contributed by
the employee or their employer
Withdrawals
- Any withdrawal from this scheme can be made regularly or in lump-sum
Enrolment
- Any individual (including children) can enrol themselves into this scheme at anytime
- Any individual can opt-out of this scheme at anytime
Contributions
- Any contribution into this scheme will be made in net i.e. 80% will be contributed by
the individual or any third party and 20% will be contributed by the HMRC
Withdrawals
- Any withdrawal from this scheme can be made regularly or in lump-sum
Charge-free contribution
- Any contribution into the pension scheme upto the tax-relievable contribution or the
annual allowance whichever is lower will be charge-free contribution
Chargeable contribution
- Any contribution into the pension scheme above the tax-relievable contribution or the
annual allowance whichever is lower will be chargeable contribution
Tax-relievable contribution
- Any contribution into the pension scheme upto £3600 or the relevant earnings whichever
is higher will be tax-relievable contribution
Annual allowance
- It is that portion of contribution into the pension scheme which is charge-free
- Any unused annual allowance can be carried forward to the three immediately succeeding
tax years
- The current tax year's annual allowance must be fully utilised before utilising the previous
tax year's annual allowance
Notes -
- It will be available to all the individuals (including children)
- It will be available in full in the year of birth and in the year of death
Chargeable withdrawals
- Any withdrawal from the pension scheme above the lifetime allowance will be chargeable
withdrawal as follows viz. -
- At 25% if the excess pension funds are withdrawn regularly
- At 55% if the excess pension funds are withdrawn in lump-sum
Chapter 08 - Share option schemes and share incentive plans
Inheritance tax will be payable on transfer Inheritance tax will be payable on transfer
made during the lifetime or due to death made during the lifetime or due to death
Notes -
- Any landlord can get their property income assessed on accrual basis even if their rental
income is ≤ £150000
- Any landlord cannot get part of their property income assessed on receipt basis and
part of their property income assessed on accrual basis
- Election to get their property income assessed on accrual basis can be made within
01 year from 31st January following the tax year
Rental income
- It comprises of income earned or received by the landlord from all the properties
Capital income
- Any income being one-time income will not be assessed as property income unless the
landlord becomes entitled to such income and it comprises of the following viz. -
- Security deposit towards unpaid rent
- Security deposit towards damages and destruction of the property
Revenue income
- Any income being regular income will be assessed as property income and it comprises
of the following viz. -
- Rent
- Any amount reimbursed by the tenant irt any expense incurred by the landlord on the
property
Allowable expenses
- It comprises of expenses incurred by the landlord irt all the properties
- Any expense incurred irt any property will be reduced proportionately in the following
cases viz. -
- If such property is part rented-out and part self-occupied
- If such property is rented-out for such rent which is less than the commercial rent
of the property
Capital expenses
- Any expense incurred on acquisition, enhancements and improvements (including incidental
costs) of any property will not be allowable expense
- Any expense incurred on furnishing and fixing of any property will not be allowable
expense
- Capital allowances irt any property will not be allowable expense
Revenue expenses
- Any expense incurred on repairing and maintaining of any property will be allowable
expense
- Any other expense incurred irt any property will be allowable expense and it comprises
of the following viz. -
- Agent's fee
- Municipal taxes
- Insurance expense
- Decoration expense
- Management expense
- Advertisement expense
- Irrecoverable debts (it will be considered on accrual basis only)
Interest paid (including bank charges) on loan taken irt any non-residential
-
property
- Travelling expense or mileage allowance (the landlord will have an option to either
deduct the expense incurred as per the actual travelling expense or as per the mileage
allowance)
Reliefs available
- It comprises of reliefs available to the landlord irt all the properties
Interest paid (including bank charges) on loan taken irt any residential property relief
- All revenue expenses incurred on interest paid (including bank charges) on loan taken
irt any residential property for the following viz. -
- Acquisition, enhancements and improvements (including incidental costs)
- Furnishing and fixing
- Repairing and maintaining
- Incurring any other expense
- Other reliefs will be available at 20% of interest paid (including bank charges) on loan
taken irt any residential property
- If the income tax liability of the landlord is less than the other reliefs available then
they cannot claim income tax refund and their balance amount will lapse
Notes -
- Any property will be considered as furnished holiday letting if -
- It is situated in the UK or the EEA
- It is available for letting-out for ≥ 210 days
- It is actually letted-out for ≥ 105 days
- It is not letted-out to the same person for ≥ 30 days continuously
- It is not letted-out to the same person for ≥ 155 days in aggregate
- Election to get their property assessed as normal property or furnished holiday letting
can be made within 01 year from 31st January following the tax year
Rental income
- It comprises of income earned or received by the individual from all the furnished holiday
lettings
Capital income
- Any income being one-time income will not be assessed as furnished holiday letting income
unless the individual becomes entitled to such income
Revenue income
- Any income being regular income will be assessed as furnished holiday letting income
Allowable expenses
- It comprises of expenses incurred by the individual irt all the furnished holiday lettings
- Any expense incurred irt any furnished holiday letting will be reduced proportionately
in the following cases viz. -
- If such furnished holiday letting is part letted-out and part self-occupied
- If such furnished holiday letting is letted-out for such rent which is less than the
commercial rent of the furnished holiday letting
Capital expenses
- Any expense incurred on acquisition, enhancements and improvements (including incidental
costs) of any furnished holiday letting will not be allowable expense
- Any expense incurred on furnishing and fixing of any furnished holiday letting will be
allowable expense
- Capital allowances irt any furnished holiday letting will be allowable expense
Revenue expenses
- Any expense incurred on repairing and maintaining of any furnished holiday letting will be
allowable expense
- Any other expense incurred irt any furnished holiday letting will be allowable expense
Reliefs available
- It comprises of reliefs available to the individual irt all the furnished holiday lettings
- Following reliefs will be available irt any furnished holiday letting viz. -
- Rollover relief
- Gift holdover relief
- Business asset disposal relief
- Pre-letting period expenses relief
- Replacement of furnishing and fixing relief
- Interest paid (including bank charges) on loan taken irt any residential property relief
Notes -
- Any property will be considered as rent-a-room letting if -
- It is furnished and fixtured
- It is part of the main residence of the individual
Notes -
- Election to get their rent-a-room letting income assessed on alternate basis or normal
basis can be made within 01 year from 31st January following the tax year
- The rental income from all the rent-a-room lettings from jointly held main residence
will be considered as exempt income under property income upto £3750 only
Grant of lease
- It is an arrangement where any landlord (lessor) can give their tenant (lessee) the right
to use their property for fixed duration and for fixed payment
Lease duration
- It is the duration of the lease arrangement and it helps in determining the type of lease
and the tax implications
Types of leases
Short-term lease
- They are the leases with lease duration of ≤ 50 years
Long-term lease
- They are the leases with lease duration of > 50 years
Lease payment
- It is the amount paid by the lessee to the lessor and it helps in determining the tax
implications
Lease premium
- Any payment being one-time payment will be considered as lease premium
Lease rentals
- Any payment being regular payment will be considered as lease rentals
Lease rentals xx
Less: Lease expenses xx
Normal property income xxxx
Grant of sub-lease
- It is an arrangement where any tenant (lessee) can give their sub-tenant (sub-lessee)
the right to use the property of the landlord (lessor) for fixed duration and for fixed
payment
Sub-lease duration
- It is the duration of the sub-lease arrangement and it helps in determining the type of
sub-lease and the tax implications
Types of sub-lease
Short-term sub-lease
- They are the sub-leases with sub-lease duration of ≤ 50 years
Long-term sub-lease
- They are the sub-leases with sub-lease duration of > 50 years
Sub-lease payment
- It is the amount paid by the sub-lessee to the lessee and it helps in determining the tax
implications
Sub-lease premium
- Any payment being one-time payment will be considered as sub-lease premium
Sub-lease rentals
- Any payment being regular payment will be considered as sub-lease rentals
Sub-lease rentals xx
Less: Sub-lease expenses xx
Normal property income xxxx
What are the tax implications for investments held in individual's savings account?
What are the tax implications for investments held in venture capital trust scheme?
Notes -
- If the investments in venture capital trust scheme are held for > 05 years then
there is no further tax implication
- If the investments in venture capital trust scheme are held for ≤ 05 years then
there are further tax implications as follows -
- If any gains arise from disposal of investments held in venture capital trust scheme
then full amount of other reliefs provided will be withdrawn
- If any losses arise from disposal of investments held in venture capital trust scheme
then full amount of other reliefs provided or 30% of disposal proceeds whichever is
lower will be withdrawn
Carry-back facility
- Claim of other reliefs irt investments held in venture capital trust scheme cannot be made
irt any unused limit of the immediately preceding tax year
Claim of other reliefs
- Claim of other reliefs irt investments held in venture capital trust scheme can be made
within 05 years from 31st January following the tax year
Notes -
- If the individual invests in more than one investment scheme during the tax year then
claim of other reliefs will be made as follows viz. -
- Investments held in venture capital trust scheme
- Investments held in enterprise investment scheme
- Investments held in seed enterprise investment scheme
What are the tax implications for investments held in enterprise investment scheme?
Notes -
- If the investments in enterprise investment scheme are held for > 03 years then
there is no further tax implication
- If the investments in enterprise investment scheme are held for ≤ 03 years then
there are further tax implications as follows -
- If any gains arise from disposal of investments held in enterprise investment scheme
then full amount of other reliefs provided will be withdrawn
- If any losses arise from disposal of investments held in enterprise investment scheme
then full amount of other reliefs provided or 30% of disposal proceeds whichever is
lower will be withdrawn
Carry-back facility
- Claim of other reliefs irt investments held in enterprise investment scheme can be made
irt any unused limit of the immediately preceding tax year as well
- This claim of other reliefs will be made by revising the income tax return of the previous
tax year
Notes -
- If the individual invests in more than one investment scheme during the tax year then
claim of other reliefs will be made as follows viz. -
- Investments held in venture capital trust scheme
- Investments held in enterprise investment scheme
- Investments held in seed enterprise investment scheme
What are the tax implications for investments held in seed enterprise investment scheme?
Notes -
- If the investments in seed enterprise investment scheme are held for > 03 years then
there is no further tax implication
- If the investments in seed enterprise investment scheme are held for ≤ 03 years then
there are further tax implications as follows -
- If any gains arise from disposal of investments held in seed enterprise investment
scheme then full amount of other reliefs provided will be withdrawn
- If any losses arise from disposal of investments held in seed enterprise investment
scheme then full amount of other reliefs provided or 50% of disposal proceeds
whichever is lower will be withdrawn
Notes -
- If the individual invests in more than one investment scheme during the tax year then
claim of other reliefs will be made as follows viz. -
- Investments held in venture capital trust scheme
- Investments held in enterprise investment scheme
- Investments held in seed enterprise investment scheme
Chapter 14 - Trust income
Trust
- It is an arrangement where any person (settlor) can transfer any asset (relevant asset)
to any group of person (trustees) for the benefit of one or more persons (beneficiaries)
Types of trusts
Discretionary trust
- The beneficiaries are unknown
- The beneficiaries have no legal right to use the assets, receive income and gains from
the assets and receive the assets
Disabled trust
- Any trust created for the direct or indirect benefit of the spouse or children
Types of beneficiaries
Life tenant
- It is the beneficiary who uses the asset and receives income from the asset
Remainder man
- It is the beneficiary who receives the asset and receives chargeable gain / loss from
the asset
If the asset enters the trust during the lifetime of the settlor
- Any gains in the hands of the settlor will be taxable gains
- Any losses in the hands of the settlor will be adjustable losses
- Disposal proceeds will be market value on the date of transfer
- Gift holdover relief will be available since inheritance tax will be payable
If the asset enters the trust during the lifetime of the settlor
- Any gains in the hands of the settlor will be taxable gains
- Any losses in the hands of the settlor will be adjustable losses
- Disposal proceeds will be market value on the date of transfer
- Gift holdover relief will be available since inheritance tax will be payable
If the asset enters the trust during the lifetime of the settlor
- Any gains in the hands of the settlor will be taxable gains
- Any losses in the hands of the settlor will be adjustable losses
- Disposal proceeds will be market value on the date of transfer
- Gift holdover relief will not be available since inheritance tax will not be payable