TSEM10235 | Non-resident trusts: trustees’ chargeability: Income Tax - accumulation and discretionary trusts
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
If the trustees of a non-resident trust have power to:
accumulate income or
pay income at their discretion or
accumulate income and pay income at their discretion
then the amount of UK-source income on which the trustees are chargeable to tax is charged at special rates under ITA07/S479.
The trustees are also taxable at the special trust rates on certain receipts that are deemed to be income under ITA07/Ss481-482 - see TSEM3201.
See TSEM3041 for trust tax rates