This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Trusts, Settlements and Estates Manual

Tax Cases: Fry v Shiels' Trustees 6 TC 583


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


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

TSEM references