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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Non-resident trusts: trustees’ chargeability: Income Tax - tax pool

TSEM3020 describes the ‘tax pool’ for UK resident trusts.

Tax paid by trustees while a trust is non-resident does not enter the tax pool. Tax goes into the pool only if it is tax paid at a time when the trustees are UK resident.

See TSEM3790 if income distributions are made to beneficiaries of non-resident trusts.