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HMRC internal manual

Trusts, Settlements and Estates Manual

From
HM Revenue & Customs
Updated
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Ownership and income tax: legal background: ownership - income follows property

The starting point is that whoever has beneficial ownership of the property (or part of the property) has beneficial ownership of the income (or the respective part of the income).

For example, if A has a beneficial interest in 75% of the property and B has a beneficial interest in 25%, you start from the basis that A is entitled to 75% of the income and B is entitled to 25%.

The direct correlation between property and income may be varied - see TSEM9170.