½Û×ÓÊÓƵ

Tax on income distributions for beneficiaries from non-resident trusts (to 5 April 2025)

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

Tax on income distributions for beneficiaries from non-resident trusts (to 5 April 2025)

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
imgtext

The concept of domicile is no longer relevant from 6 April 2025. This note details the position before this date. For the rules that apply from 6 April 2025 see the Tax on income distributions for beneficiaries of non-resident trusts (6 April 2025 onwards) guidance note.

Introduction

The tax liabilities of UK resident beneficiaries of non-resident trusts are governed by a series of ‘tax hierarchy’ rules. See the Tax on UK resident beneficiaries of non-resident trusts (overview) guidance note.

The first step is to establish whether:

  1. •

    the beneficiaries’ entitlement under the trust is fixed or discretionary, and

  2. •

    any payment is capital or income

The nature of the beneficiaries’ interest will help to determine what type of payment it is. This is discussed further in the Tax on UK resident beneficiaries of non-resident trusts (overview) guidance note.

Payments of and entitlement to income are subject to income tax according to the principles set out in this guidance note.

There are special

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+â„¢
Powered by

Popular Articles

Exemption ― burial and cremation

Exemption ― burial and cremationThis guidance note provides an overview of the VAT treatment of services that are provided in connection with the burial or cremation of human remains.VAT treatmentThe following services are exempt from VAT:•the disposal of the remains of the dead•making arrangements

14 Jul 2020 11:38 | Produced by Tolley Read more Read more

Non-trading deficits on loan relationships

Non-trading deficits on loan relationshipsOverview of non-trading deficits (NTDs)When a company’s debits on its non-trading loan relationships and derivative contracts in an accounting period exceed the credits on its non-trading loan relationships and derivative contracts in the same period (the

14 Jul 2020 12:17 | Produced by Tolley Read more Read more

Furnished holiday lets

Furnished holiday letsThis guidance note sets out the qualifying conditions for a property let to be treated as a furnished holiday let (FHL) for tax purposes and the subsequent tax implications.Whether or not a property qualifies as an FHL can make an important difference to the taxation

14 Jul 2020 11:46 | Produced by Tolley Read more Read more