Beneficial intrest transfer and TSEM4200

I purchased a rental property as tenants in common with one of my sons, with 80% shares in his favour. There is an outstanding mortgage of 40%. Because I am a low-income retiree, my son, who has a high income, wants to transfer all beneficial interest to me to supplement my pension. He proposed the following conditions as a business arrangement: a) I take on the responsibility of managing property and absorb all costs associated with rental and maintenance b) The mortgage will be paid out of rental income c) To compensate his lost income, in addition to a), my shares of this property will be transferred exclusively to him as part of the inheritance estate. Would TSEM4200 - Settlements legislation apply to such an arrangement? Your expert advice would be most appreciated.

Hi Glenda,
Thank you for your question.
I refer you to HS270 - 
HS270 Trusts and settlements - income treated as the settlor's (2024) if any 1 of the 3 situations described in point 1 of the help sheet apply then your son would be liable to tax as a settlor as described in:
TSEM4200 Settlements legislation: settlor retains an interest.
Thank you.