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HMRC internal manual

Trusts, Settlements and Estates Manual

Tax Cases: Carver v Duncan STC 356

Summary

The trustees paid insurance premiums to protect against CTT liability. There were powers in the trust document to permit the payments.

Decision

The payments were not trust expenses deductible under FA/73S16 (2)(d).

TSEM references

 TSEM8105, TSEM8110, TSEM8115, TSEM8125, TSEM8130, TSEM8140, TSEM8230, TSEM8235, TSEM8740, TSEM8747