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HMRC internal manual

Trusts, Settlements and Estates Manual

Non-resident trusts: trustees’ chargeability: Income Tax - accumulation and discretionary trusts

If the trustees of a non-resident trust have power to:

  • accumulate income or
  • pay income at their discretion or
  • accumulate income and pay income at their discretion

then the amount of UK source income on which the trustees are chargeable to tax is charged at special rates under ITA/S479.

The trustees are also taxable at the special trust rates on certain receipts that are deemed to be income under ITA/Ss481-482 - see TSEM3201.

See TSEM3041 for trust tax rates