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HMRC internal manual

Trusts, Settlements and Estates Manual

Non-resident trusts: beneficiary’s chargeability: introduction

This section considers the United Kingdom tax liabilities arising to UK-resident beneficiaries of non-resident trusts. In particular it looks at:

  • Beneficiaries of bare trusts - see TSEM10410
  • Beneficiaries with an entitlement to trust income - interest in possession trusts (IIP) trusts - see TSEM10415 to IHTM10430
  • Beneficiaries who may receive trust income at the trustees’ discretion - discretionary trusts - see TSEM10435 to TSEM10455
  • Capital distributions made to beneficiaries - see TSEM10460