INTM367790 - DT applications and claims: Non-resident beneficiaries of UK trusts
What methods of relief are available on discretionary payments from UK resident trustees
»Ê¹ÚÌåÓýapp way in which relief is calculated will depend on the terms of the treaty under which relief is claimed.
- Under an ‘other income� article which does not exclude payments from trusts, relief is given in full. A list of these countries is at INTM367800
- Where there is no other income article or the article excludes trust income, relief is given by ‘looking throughâ€� to the underlying sources of the income. »Ê¹ÚÌåÓýapp way in which we ‘look throughâ€� is determined by Extra Statutory Concession (ESC) B18.
- Because payments are made at the discretion of trustees, it is not possible to allow relief at source to a beneficiary of a discretionary trust.