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HMRC internal manual

Trusts, Settlements and Estates Manual

From
HM Revenue & Customs
Updated
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Trust income and gains: Accrued Income Scheme: change of trustees

Trustees remain resident in the UK

There are no Accrued Income Scheme consequences when trustees change, but the trustees of the settlement remain resident in the UK. The change simply produces self-cancelling deemed profits and losses.

Trustees change from resident to non-resident

As the new trustees are not resident, they do not satisfy the ‘residence requirement’ of the Accrued Income Scheme. The appointment of non-resident trustees is a transfer of the securities by the resident trustees.

For the purposes of the Transfer of Assets Abroad legislation ITA 2007 ensures that any liability under ITA 2007 takes proper account of charges and allowances profits and losses under the Accrued Income Scheme

Trustees change from non-resident to resident

As the old trustees were not resident, they do not satisfy the ‘residence requirement’ of the Accrued Income Scheme. The change of trustees is a transfer of securities to the resident trustees.