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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust management expenses: bare trusts: general

Where a bare trust exists, the beneficiary has an absolute right to trust capital and income as it arises. So the beneficiary’s entitlement for tax purposes is the gross income of the trust before expenses the trustees incur.

The beneficiary shows the gross trust income on his or her personal return. He or she must not deduct the expenses that the bare trustees pay, because the income used to pay those expenses is income that belongs to the beneficiary.

The general position is therefore that bare trusts do not have any allowable TMEs. But see TSEM8410.