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HMRC internal manual

Trusts, Settlements and Estates Manual

Non-resident trusts: trustees’ chargeability: Income Tax - FOTRA securities

FOTRA stands for ‘Free of Tax to Residents Abroad’. The securities involved are British Government gilts.

If HMRC has confirmed that interest paid to the trustees of a non-resident trust on FOTRA securities is exempt from charge, then no tax is due.

Otherwise the effect of ITA/S811 (TSEM10215) is considered in respect of a charge to tax on such interest.