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HMRC internal manual

Trusts, Settlements and Estates Manual

Tax Cases: CIR v Hamilton of Dalzell (Lord) 10 TC 406

Summary

The taxpayer had a life interest in the trust income after expenses. The trust deed allowed him to receive the full income and pay the expenses himself.

Decision

His income for surtax purposes was the income after expenses.

TSEM references

TSEM8320