Taxation of Chargeable Gains Act 1992 section 169E

Meaning of "settlor" in sections 169B to 169D and 169G

Section 169E defines who counts as a "settlor" for the purposes of the rules that restrict hold-over relief on gifts to settlements in which the settlor retains an interest.

• A settlor is an individual who has contributed property — directly or indirectly — to a settlement, and the settled property consists of or includes that contributed property
• Property "originating from" the settlor covers both the property originally provided and any property that wholly or partly represents it, including accumulated income derived from it
• Where someone else provides property to a settlement under a reciprocal arrangement with the settlor, that property is treated as originating from the settlor
• Conversely, where the settlor provides property under a reciprocal arrangement made for another person's benefit, that property is not treated as originating from the settlor