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HMRC internal manual

Trusts, Settlements and Estates Manual

Trust management expenses: allowable expenses: specific items: running costs

Where - typically in larger trusts, such as those established by a business for the benefit of its employees - the method of administration of the trust involves maintaining an office, the attendant expenses are not properly chargeable to income. Such expenses include salaries of personnel, expenses of accommodation, cleaning, and maintenance of equipment and premises. These are the expenses of the operation of the trust as a whole, and so properly chargeable to capital on normal principles.

The fact that such charges may be recurrent does not affect that fact that they are incurred for the benefit of the trust as a whole and hence capital.