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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Trust income and gains: relief for overseas tax: trust income deemed not to be the beneficiary's

For tax purposes, income may be deemed to be that of someone other than a beneficiary. Forexample, the anti-avoidance provisions may treat trust income as that of the settlor. Thetrustees can claim tax credit relief on the income.

If the trustees do not claim relief, the overseas income chargeable is the net amountafter deduction of overseas tax.