Income Tax Act 2007 section 511

Prevention of double taxation: reimbursement of settlor

Section 511 prevents a double charge to income tax where a settlor is reimbursed from heritage maintenance property income for property maintenance expenditure that is also deductible in calculating trade or UK property business profits.

• Applies where heritage maintenance property income is treated as the settlor's income under the settlements legislation and is used to reimburse the settlor for property maintenance expenditure
• The expenditure being reimbursed must be deductible in calculating the profits of a trade or UK property business carried on by the settlor
• The reimbursement income is not brought into account as a receipt when calculating the profits of that trade or property business, preventing it from being taxed twice
• The income is not treated as the settlor's income for any purpose other than under the settlements legislation in Chapter 5 of Part 5 of ITTOIA 2005