SolvedTSEM10225 | Non-resident trusts: trustees’ chargeability: Income Tax - FOTRA securities
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
FOTRA stands for ‘Free of Tax to Residents Abroad’. The securities involved are British Government gilts.
If HMRC has confirmed that interest paid to the trustees of a non-resident trust on FOTRA securities is exempt from charge, then no tax is due.
Otherwise the effect of ITA07/S811 (TSEM10215) is considered in respect of a charge to tax on such interest.