SolvedTSEM7032 | Tax Cases: HMRC v Peter Clay STC 469
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
Summary
Trustees incurred expenses, including trustees’ fees, and charged some against income.
Decision
Expenses for the benefit of the whole estate are chargeable to capital in general trust law and cannot be charged or apportioned to income. Only expenses that are exclusively for the benefit of the income beneficiaries are chargeable to income in general trust law.