Taxation of Chargeable Gains Act 1992 Schedule 5 paragraph 7

Meaning of "settlor"

Schedule 5 paragraph 7 defines who counts as a "settlor" for the purposes of attributing trust gains to UK-resident individuals under section 86.

• A person is a settlor if the trust property includes property that originated from them.
• The definition applies specifically in the context of section 86 and Schedule 5 (attribution of gains to settlors with an interest in non-resident or dual-resident settlements).
• It is not necessary for all the trust property to have come from the person — it is sufficient that the trust property includes some property originating from them.
• This broad definition means that anyone who has contributed assets or funds to a settlement may be treated as a settlor for capital gains attribution purposes.