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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: vulnerable beneficiaries - non-resident trustees

The vulnerable beneficiary regime is not restricted to trustees who are resident or ordinarily resident in the UK. Trustees who are not resident or ordinarily resident in the UK in a tax year will normally be liable to income tax at the special trust rates only in respect of income arising in the UK and will be able to claim the special income tax treatment where the necessary conditions are met.

It is the income arising in the UK alone which is taken into account in calculating any deduction from the trustees’ income tax liability.

If the trustees are not resident or ordinarily resident in the UK in a tax year for CGT purposes the special capital gains tax treatment does not apply.