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HMRC internal manual

Trusts, Settlements and Estates Manual

Tax Cases: HMRC v Peter Clay STC 469

Summary

Trustees incurred expenses, including trustees’ fees, and charged some against income.

Decision

Expenses for the benefit of the whole estate are chargeable to capital in general trust law and cannot be charged or apportioned to income. Only expenses that are exclusively for the benefit of the income beneficiaries are chargeable to income in general trust law.

TSEM references

TSEM8100, TSEM8105, TSEM8120, TSEM8125, TSEM8130, TSEM8135, TSEM8140, TSEM8145, TSEM8150, TSEM8730, TSEM8735, TSEM8740, TSEM8786