TSEM10245 | Non-resident trusts: trustees’ chargeability: Income Tax - trust management expenses
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
You can find detailed guidance in TSEM8000+, as to whether trust management expenses are allowable and are to be taken into account for tax purposes in order to:
tax accumulation/discretionary trustees at rates lower than the special trust rates,
arrive at the net amount of income of a beneficiary of an interest in possession trust
Rules specific to non-resident trusts are described in TSEM10250.