TSEM3425 | Trust income and gains: vulnerable beneficiaries - non resident vulnerable person
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
A vulnerable person is resident in the UK if they are resident here for any part of the tax year.
A vulnerable person is not UK resident if they are not resident here for any part of the tax year.
A beneficiary does not have to be resident in the UK to be a vulnerable person for the purposes of the special tax regime. The place of residence makes no difference to the question as to whether the beneficiary is regarded as being a vulnerable person on the basis of:
being a relevant minor, or
being a disabled person owing to mental disorder.