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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust income and gains: vulnerable beneficiaries - vulnerable person election

A separate election is needed for each vulnerable person for whom the trustees wish to claim the special tax treatment.

An election is irrevocable and has effect from the effective date (TSEM3456) till one of the following events occurs:

  • the person in relation to whom the election is made ceases to be a vulnerable person
  • the trusts in relation to which the election is made cease to be qualifying trusts, or
  • the trusts are terminated

The trustees must inform HMRC where they become aware that one of these events has happened. They must do so in writing, giving full details of the event, within 90 days of first becoming aware of the event. See TSEM3484 regarding failure to give notice.