[721A Meaning of “protected foreign-source income” in section 721]

[721A  Meaning of “protected foreign-source income” in section 721]

[(1)     This section has effect for the purposes of rule 2 of section 721(3B) (cases where the individual is not UK domiciled and is not deemed domiciled by virtue of Condition A in section 835BA).

(2)     The income of the person abroad is “protected foreign-source income” so far as it is within subsection (3) or (4).

(3)     Income is within this subsection if—

(a)     it would be relevant foreign income if it were the individual's,

(b)     the person abroad is the trustees of a settlement,

(c)     the trustees are non-UK resident for the tax year,

(d)     when the settlement is created, the individual is—

(i)     not domiciled in the United Kingdom, and

(ii)     if the settlement is created

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