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HMRC internal manual

Trusts, Settlements and Estates Manual

Non-resident trusts: trustees’ chargeability: introduction

The basic position is that:

  • Non-resident trustees are taxable on United Kingdom source income only
  • Non-resident trustees are potentially not taxable on capital gains for a year the whole of which the trust is a non-resident trust.

TSEM10210 - TSEM10260 deals with Income Tax

TSEM10265 - TSEM10275 deals with Capital Gains Tax