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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Trust income and gains: beneficiaries: individual beneficiary receives discretionary income payment from a resident trust: when payment made

For tax purposes the beneficiary receives a payment on:

  • The date the trustees made the payment or
  • The date the beneficiary became legally entitled to require the trustees to pay over the income. This could be when the payment indefeasibly vested, following the trustees’ resolution.

Tax cases

Cunard’s Trustees v CIR 27 TC 122