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HMRC internal manual

Trusts, Settlements and Estates Manual

Non-resident trusts: trustees’ chargeability: Income Tax - interest in possession trusts

The trustees of a non-resident IIP trust are chargeable at the basic rate on the trust’s UK source income, without any deduction for trust management expenses.

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