Commentary

I5.1215 Income tax liability of non-resident trustees

IHT, trusts and estates

I5.1215 Income tax liability of non-resident trustees

Tax liabilities of non-resident trustees

I5.1215 Income tax liability of non-resident trustees

Non-resident trustees' chargeability to UK income tax

The trustees of a non-resident trust are chargeable to UK income tax on UK-source income arising to the trust1. They are not chargeable to UK income tax on any foreign income arising to the trust. In certain circumstances the settlor of the trust may be chargeable on the trust income instead of the trustees2 (see I5.1220).

Under the statutory residence test (applying for 2013/14 onwards) (see Division E6.13), a trust cannot split the tax year when a trustee's residence position changes, and is either resident or non-resident for the whole tax year (see I5.1207).

Income chargeable on non-resident trustees

The amount of any UK income

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