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HMRC internal manual

Trusts, Settlements and Estates Manual

Seeking technical advice from Trusts Technical


Technical specialists based in Bootle and Edinburgh are part of Trusts Technical.  They advise on the issues covered by the TSEM. Their subject areas are:

  • UK resident trusts and Income Tax
  • non-resident trusts
  • the settlements legislation
  • deceased estates administration periods
  • beneficial ownership and Income Tax

For a full list of subjects see below.

Specialists in Trusts Technical do not advise on Capital Gains Tax for UK resident trusts or on Inheritance Tax (IHT).  Refer any doubt, difficulty or dispute on other taxation points (for example trade profits, property income or chargeable gains) to the relevant specialist office for advice.

Trusts Technical specialists provide advice to HMRC colleagues and do not usually communicate directly with taxpayers or agents, although they may do so on occasion.

Trusts Technical subject list and office

Subject TSEM reference Trusts Technical office
Income Tax and trusts   Edinburgh
Law of England and Wales trust deeds and questions on the reading of trust deeds   Edinburgh
Scots law trust deeds and questions on the reading of trust deeds   Edinburgh
Whether a trust exists/whether a trust is valid (other than in the context of TCGA92/S225) TSEM1006 Edinburgh
Interest as an allowable trust management expense TSEM8730  
TSEM8735 Bootle    
  Trust management expenses issues not covered by TSEM guidance TSEM8000+ Bootle
  Non-resident vulnerable person who is physically disabled TSEM3426 Edinburgh
  Vulnerable beneficiaries - notice of determination TSEM3481 Edinburgh
  Other vulnerable beneficiaries issues not covered by TSEM guidance TSEM3400+ Edinburgh
  Mineral royalties received by trustees TSEM3196 Bootle
  Woodlands expenses TSEM8790 Bootle
  Potential rectification cases TSEM1902 Edinburgh
  Potential mistake cases TSEM1903 Nottingham
  Potential Hastings Bass cases TSEM1904 Bootle
  Trusts for particular purposes TSEM5000+ Edinburgh
  Effect of the application of foreign law TSEM10420 International Bootle
  Residence of trustees TSEM10000+ International Bootle
  Non-resident trusts    
  Non-resident trusts - branch, agency or permanent establishment TSEM10055+  
Appendix 1 International Bootle    
  Non-resident trusts and Capital Gains Tax   International Bootle
  Extra statutory concession A93   International Bootle
  Extra statutory concession B18   International Bootle
  Transfer of assets abroad   International Bootle
  Settlements legislation apart from capital sums paid to settlor TSEM4000+ Edinburgh
  Settlements legislation capital sums paid to settlor TSEM4400+ Edinburgh
  Income Tax repayments to minor children - RM3680 onwards, including cases where a pension is payable to a minor child following the death of a parent   Edinburgh
  Estates in administration TSEM7350+ Edinburgh
  Questions about whether the individual(s) occupying a private residence held by personal representatives had a ‘relevant entitlement’ in the whole or any part of the net proceeds of disposal (s225A TCGA 1992)   Edinburgh
  Income Tax issues arising from the ownership or joint ownership of property - this could include tax on rental income, bank or building society interest, or dividends TSEM9000+ Edinburgh
  Bare trusts and declarations   Edinburgh

Requesting help from Technical and Valuation

Full details of when and how to request help from Technical and Valuation is available .  This included guidance for requesting technical help and guidance for completing the template on SEES.