[SCHEDULE 4C Transfers of Value: Attribution of Gains to Beneficiaries]

[SCHEDULE 4C Transfers of Value: Attribution of Gains to Beneficiaries]

[Section 85A]

[[Introduction

1

(1)     This Schedule applies where the trustees of a settlement (“the transferor settlementâ€) make a transfer of value to which Schedule 4B applies (“the original transferâ€).

[(2)     The transferor settlement is regarded for the purposes of this Schedule as having a “Schedule 4C poolâ€.

(3)     The Schedule 4C pool contains [the section 1(3) amounts] for the settlement that are outstanding at the end of the tax year in which the original transfer is made (see paragraph 1A).

(3A)     [The section 1(3) amount] for that tax year is increased by—

(a)     the amount of Schedule 4B trust gains accruing by virtue of the original transfer (see paragraphs 3 to 7), and

(b)     the total amount of any further Schedule 4B trust gains accruing by virtue of any further transfers of value to which that Schedule applies that are made by the trustees in that tax year.]

(4)     Paragraphs 8 to 9 provide for the attribution of gains in a settlement's Schedule 4C pool.

(5)     References in this Schedule to a transfer to which Schedule 4B applies include any such transfer, whether or not any chargeable

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