TSEM4550 - Settlements legislation: trustee or beneficiary entitled to share tax repayment


Where the operation of the Settlements legislation results in a repayment to the settlor in excess of any repayment otherwise due, the settlor should pay that excess to the trustee or other person who received the income. If there is any dispute about the amount or the apportionment of the repayment, the matter is to be decided by the General Commissioners. Their decision is final.

Tax offices should limit their action to certifying facts to


  • the settlor on request, and
  • the General Commissioners where their decision is requested.