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HMRC internal manual

Trusts, Settlements and Estates Manual

From
HM Revenue & Customs
Updated
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Trust management expenses: IIP trusts: IIP beneficiaries: tax law: order of set-off

ITA/S503(2) provides the order of set-off for TMEs to reduce the income of an IIP beneficiary. The order of set-off of TMEs in an IIP beneficiary’s tax calculation is the same as for accumulation/discretionary trustees (TSEM8250). But there is no grossing up of expenses as there is for accumulation/discretionary trustees.