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HMRC internal manual

International Manual

DT applications and claims: Non-resident beneficiaries of UK trusts

What methods of relief are available on discretionary payments from UK resident trustees

The way in which relief is calculated will depend on the terms of the treaty under which relief is claimed.

  • Under an ‘other income’ article which does not exclude payments from trusts, relief is given in full. A list of these countries is at INTM367800
  • Where there is no other income article or the article excludes trust income, relief is given by ‘looking through’ to the underlying sources of the income. The way in which we ‘look through’ is determined by Extra Statutory Concession (ESC) B18.
  • Because payments are made at the discretion of trustees, it is not possible to allow relief at source to a beneficiary of a discretionary trust.