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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Tax Cases: Miller (Lady) v CIR 15 TC 25


Trustees held a property for the use of the beneficiary. She lived in it ‘free of rent and taxes’. The trustees paid all outgoings of the house and the estate.


The beneficiary was assessable to surtax on

  • the amount assessable Schedules A & B (1919-20)
  • the rates that the trustees paid. The assessable amount was the rates, plus income tax thereon.

TSEM references