TSEM8250 | Trust management expenses: accumulation/discretionary trusts: order of set-off
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
ITA/S486(1) provides the order in which expenses are to be set against income. Allowable TMEs are set against income chargeable to the special rates of tax in ITA/S479 in this order:
against dividend income of the type specified in ITA/S486(2) for example dividends and stock dividends from UK resident companies,etc, then
any excess against other dividend income not within S486(2), then
any excess against savings income, finally
any excess against other income.
See example in TSEM8255.