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HMRC internal manual

Trusts, Settlements and Estates Manual

From
HM Revenue & Customs
Updated
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Tax Cases: Fry v Shiels' Trustees 6 TC 583

Summary

Trustees carried on a business on behalf of minor beneficiaries. They passed the profits to the beneficiaries.

Decision

The profits were not directly earned by the beneficiaries, and were not their earned income.

TSEM references

TSEM3195