TSEM8360 | Trust management expenses: IIP trusts: IIP beneficiaries: tax law: order of set-off
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
ITA/S503(2) provides the order of set-off for TMEs to reduce the income of an IIP beneficiary. The order of set-off of TMEs in an IIP beneficiary's tax calculation is the same as for accumulation/discretionary trustees (TSEM8250). But there is no grossing up of expenses as there is for accumulation/discretionary trustees.