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HMRC internal manual

International Manual

HM Revenue & Customs
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DT applications and claims: Non-resident beneficiaries of UK trusts

Confidentiality when advising a beneficiary or agent about a payment

A beneficiary of a discretionary trust has no rights against the income of the trust. Trustees may favour one beneficiary rather than another. Therefore, to give a beneficiary details about the income of a trust would infringe the trustees’ confidentiality.

Because of this we cannot provide a breakdown of the underlying income comprising the repayment. The claimant (and their agent) only has a right to the final figure of the repayment we have calculated. However, if the beneficiary obtains the written permission of a trustee we can release information concerning the underlying trust income.

Sometimes a trustee will act as the nominated agent of the beneficiary. In that case you can release details of the computation to the trustee without seeking further written permission. If you are providing this information, you will need to show a full calculation. If the original apportionment of income was calculated using the computer program, you will need to make a full manual calculation (see INTM367880).