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HMRC internal manual

Trusts, Settlements and Estates Manual

Tax Cases: Cunard's Trustees v CIR 27 TC 122


Under the terms of a trust, the trustees were required to make payments out of capital to supplement the income of the beneficiary.


The payments were income when received by the beneficiary. The payments were a new source of income.

TSEM references

TSEM3756, TSEM3758, TSEM3759, TSEM3787