Question re remittance

[maths]

Note also the quote refers exclusively to income tax.

We were discussing only CGT.

The settlor interested rules are different for each tax.

[joepubli]

I think you have misread the quote.

The quote confirms the settlor is subject to tax if the arising basis applies (ie if although a non-dom the remittance basis is not formally claimed as is now necessary) but if the remittance basis is claimed then taxability depends upon actual remittance.

Umm - this means that the Non dom UK resident Settlor, even if he has no other overseas income or capital gain of his own has to claim the remittance basis and pay the £30k even though he doesn't actually benefit from the trust gains or income? Even if the settlor is excluded he doesn't escape it as "settlor interested" is widely defined? If this is the case, will need to find a way of avoiding these income and gains

[maths]

Umm - this means that the Non dom UK resident Settlor, even if he has no other overseas income or capital gain of his own has to claim the remittance basis and pay the £30k even though he doesn't actually benefit from the trust gains or income

Correct.

Even if the settlor is excluded he doesn't escape it as "settlor interested" is widely defined? If this is the case, will need to find a way of avoiding these income and gains

ITTIOA s625.