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HMRC internal manual

International Manual

DT applications and claims: FOTRA securities

FOTRA and trusts – claims by trustees

Repayment claims
Totality of interest

Repayment claims {#}

You may receive FOTRA claims

  • on form A1 by trustees not resident in the UK
  • on form A1 by UK resident trustees
  • on form C8 from a UK bank on behalf of non-resident trustees.

In all cases you must pass any FOTRA claim by a trustee whether resident in the UK or not to Business Support Group (trust team leader) who will consult Technical Advice Group.

There is guidance about claims by non-resident trustees beginning at INTM339500. This will help you identify claims by non-resident trustees.

Exemption {#}

You may also receive requests, usually by letter, from trustees or their representatives for exemption from UK income tax on their FOTRA holdings. Again you must pass all such requests to the O Caseworkers (trusts & estates specialist) who will consult Technical Advice Group before granting the exemption.

Totality of interest {#}

Trustees, whether resident in the UK or non-resident, of discretionary trusts who hold FOTRA securities may claim the FOTRA exemption provided that they can demonstrate that all currently identifiable members of the beneficial class are not ordinarily resident in the UK.