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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust income and gains: beneficiaries: company beneficiary receives discretionary income payment from a resident trust

  • CTA2010/S610 deals with discretionary payments by trustees to companies. Where the company is chargeable to corporation tax, and is not a charity, a heritage body or a scientific research organisation. payments are left out of account in calculating the profits of the company for CT purposes
  • no set-off of income tax credit under ITA/S494 is allowed against the company’s CT or income tax payable by it
  • no repayment is to be made to the company in respect of the amount treated as paid by the recipient under ITA/S494.