Amendments made: 60, in schedule 12, page 238, leave out lines 21 to 23 and insert—

“(b) the original recipient—

is liable neither to income tax nor to capital gains tax by reference to the amount or value of the original benefit, or

is a qualifying new resident for the tax year in which the original benefit is provided,”.

This amendment expands the scope of the onward gifting rule to circumstances where benefits are routed via individuals who are UK resident but who are not themselves within the scope of the benefits charge (because they are not the settlor or a close family member).

Amendment 61, in schedule 12, page 239, line 41, at end insert—

“(5A) Where the original recipient is liable neither to income tax nor to capital gains tax by reference to the amount or value of part only of the original benefit, this section applies as if the two parts of the original benefit were separate benefits.”—

Schedule 12, as amended, agreed to.