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Contents

Official guidance
Trusts, Settlements and Estates Manual

TSEM8200 · Trust management expenses: accumulation/discretionary trusts

  • TSEM8205 · Introduction
  • TSEM8210 · Basic rate, etc tax
  • TSEM8215 · Relief against the special trust rates
  • TSEM8220 · Legislation: ITA/S484: Trustees’ expenses to be set against trustees’ trust rate income
  • TSEM8225 · ITA/S484: ‘expenses of the trustees’
  • TSEM8230 · Trust deed
  • TSEM8235 · Difference between trust law and ITA/S484
  • TSEM8240 · Trust management expenses: how expenses are taken into account: accumulation/discretionary trusts: ITA/S484: basis of allowance
  • TSEM8245 · Grossing up
  • TSEM8250 · Order of set-off
  • TSEM8255 · Grossing up and order of set-off example
  • TSEM8260 · Relief against the special trust rates: deemed income
  1. Trust management expenses: accumulation/discretionary trusts: contents
  2. Trust management expenses: accumulation/discretionary trusts: grossing up and order of set-off example

TSEM8255 | Trust management expenses: accumulation/discretionary trusts: grossing up and order of set-off example

From HM Revenue & Customs · Trusts, Settlements and Estates Manual

An accumulation/discretionary trust has income as follows:

IncomeAmountNet
Dividends£900net
Bank interest£8,000net (£2,000 tax deducted at source)
It has spent£1,200on allowable TMEs.

TMEs are set first against dividend income, and any excess against the savings income.

DividendsAmountBank interestAmount
Dividends gross£1,000bank interest gross£10,000
less TMEs grossed\nup at dividend rate---
(900 × 100) ÷ 90 =£1,000--
excess TMEs(300)excess TMEs grossed up at basic rate (300 × 100) ÷ 80 =£375
---£9,625

There is nothing chargeable at the dividend trust rate, as this income is covered by the grossed-up TMEs. The bank interest £10,000 is taxable:

Interesttax ratesTotal
£375at basic rate due to TMEs£75
£1,000at basic rate due to standard rate band£200
£8,625at trust rate£4,312.50
-Total£4,587.50

As this income has already suffered tax at the basic rate (20%) the further tax to pay is £2,587.50.

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