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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 vulnerable person

A vulnerable person is resident in the UK if they are either resident here for any part of the tax year or ordinarily resident during the tax year.

A vulnerable person is not UK resident if they are neither resident here for any part of the tax year or ordinarily resident during the tax year.

A beneficiary does not have to be resident in the UK to be a vulnerable person for the purposes of the special tax regime. The place of residence makes no difference to the question as to whether the beneficiary is regarded as being a vulnerable person on the basis of:

  • being a relevant minor, or
  • being a disabled person owing to mental disorder.