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HMRC internal manual

International Manual

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

Relief on discretionary payments made by UK resident trustees where no relief is available under an ‘other income’ article

The gross amount of a discretionary payment to a beneficiary is an annual payment (TSEM3755). Where a treaty contains no provision to relieve an annual payment made by trustees, there is no statutory entitlement to relief.

However, HM Revenue & Customs operates an Extra Statutory Concession, ESC/B18, to enable relief to be considered by reference to the treaty provisions applying to the underlying sources of trust income.