Section 735AA — Income Tax Act 2007: Settlements to which following sections apply

Settlements to which following sections apply 735AA 1 Sections 735AB to 735C apply if—

a a relevant transfer occurred before 6 April 2025, b the person abroad was—

i the trustees of a settlement, or ii a company in which the trustees of a settlement were participators or indirect participators, and c protected foreign-source income or transitionally protected income arose in relation to the transfer.

2 In sections 735AB to 735C— “ the relevant transfer ” means the transfer referred to in subsection (1)(a); “ the settlement ” means the settlement referred to in subsection (1)(b)(i) or (ii) (as the case may be); “ the settlor ” means the settlor of that settlement.

3 For the purposes of subsection (1)(b)(ii), the trustees of a settlement are “indirect participators” in a company if they are participators in the first in a chain of two or more companies where the last company in the chain is the person abroad and where each company in the chain (except the last) is a participator in the next company in the chain.