Commentary on Sections Overview Chapter 3: Exemptions relating to interest on securities Section 680: Interest on securities involving accrued income losses: foreign trustees
2011.This section provides an exemption for a settlor chargeable under Chapter 5 of Part 5 of ITTOIA if the settlor would have benefited from exemption under section 679 had the foreign trustees of the settlement in question been resident or domiciled in the United Kingdom. It is based on section 720(7) of ICTA.
2012.This section complements section 667 in Chapter 2.
2013.Subsection (2) confirms that the amount of relief given against a charge under Chapter 5 of Part 5 of ITTOIA is equal to the amount of the settlor’s income under that Chapter that would have benefited from exemption under section 679 if the trustees had been resident in the United Kingdom or domiciled in the United Kingdom. (That is, by virtue of their actual residence status, the trustees are likely to be excluded transferors or transferees under section 643 and accrued income profits will therefore not arise to them, so that the condition in section 679(1)(b) is not met.)
2014.See again Change 107 in Annex 1.