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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust management expenses: accumulation/discretionary trusts: ITA/S484: ‘expenses of the trustees’

To meet the requirements in ITA/S484, allowable TMEs must be expenses of the trustees. The expenses must arise from the role of trustee, and occur in the course of exercising the duties and powers of a trustee, not from any other role such as trader.