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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust income: resident trustees with trust income from abroad: beneficiary is not resident

These instructions apply only if the beneficiary has an absolute interest in trust income (TSEM6204). This includes a life tenant and an annuitant.

The trustees’ income tax liability is based on the beneficiary’s residence position. Trustees are not chargeable in respect of the share of income from abroad payable to the non-resident beneficiary. They exclude it from the Trust and Estate Tax Return.

Tax case

Williams v Singer & others 7 TC 387