TSEM3755 | Trust income and gains: beneficiaries: company beneficiary receives discretionary income payment from a resident trust

CTA2010/S610 deals with discretionary payments by trustees to companies. Where the company is chargeable to corporation tax, and is not a charity, a heritage body or a scientific research organisation. payments are left out of account in calculating the profits of the company for CT purposes

no set-off of income tax credit under ITA/S494 is allowed against the company’s CT or income tax payable by it

no repayment is to be made to the company in respect of the amount treated as paid by the recipient under ITA/S494.