TSEM3185 - Trust income: FOTRA securities - resident trustees

FOTRA stands for 'Free of Tax to Residents Abroad'. »Ê¹ÚÌåÓýapp securities involved are British government gilts. From 6 April 1998 all interest on such securities is paid gross.Ìý

Trustees of non-bare trustsÌý

Trustees in receipt of FOTRA income need to know whether or notÌýto Self-Assess liability on the trust return. ITTOIA/S715 provides that where:Ìý

  • all the beneficiaries are not ordinarily resident in the UK (where securities were acquired before 6 April 2013) or
  • all the beneficiaries are not resident in the UK (where securities were acquired after 5 April 2013).

the trustees are treated as being the beneficial owner of the securities and exempt from tax on the income. S715(3) and (4) define ‘beneficiaries of the trustâ€� widely so as toÌýcover beneficiaries of discretionary and accumulation trusts as well as IIP beneficiaries. »Ê¹ÚÌåÓýapp trustees should exclude from the income from the trust return income.Ìý

In any other circumstances the interest is taxable. It must go on the trust returns.Ìý