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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust management expenses: ‘properly chargeable to income’ in general trust law: HMRC v Peter Clay: ‘the income beneficiaries’

While the Clay case was about accumulation/discretionary trusts, it covers trust management expenses in general trust law, and as such applies to interest in possession trusts too. So by ‘income beneficiaries’ is meant discretionary income beneficiaries and IIP beneficiaries.