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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Trust income and gains: beneficiaries: beneficiary entitled to trust income - deemed income - beneficiary is effectively the owner of the property

The terms of a trust may, in effect, confer the privilege of ownership on a beneficiary. In these circumstances the property income, including premiums treated as rent, is chargeable on the beneficiary personally.