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Trust Taxation Simplified: A Practical Guide for Accountants

· 19 min

Executive Summary

UK trust taxation operates through three distinct but interacting charging regimes -- income tax, capital gains tax, and inheritance tax -- each governed by separate legislation and compliance obligations. For 2025-26, discretionary trusts face income tax at 45%/39.35% (non-dividend/dividend) under ITA 2007 ss 479-481, CGT at a unified 24% with a GBP 1,500 annual exempt amount, and up to 6% periodic IHT charges under IHTA 1984 ss 64-66. Forthcoming changes compound the compliance challenge: the dividend ordinary rate for interest in possession trusts rises from 8.75% to 10.75% from April 2026, savings and property trust rates increase to 47% from April 2027, and trusts receive a GBP 2.5 million APR/BPR allowance from April 2026. This article provides an integrated three-regime compliance framework with worked examples, addressing the SA900, Trust Registration Service, and AEOI obligations that accountants must manage concurrently.

1. Introduction

Trust taxation in the United Kingdom presents accountants with a distinctive professional challenge: three separate charging regimes, administered through different HMRC manuals (TSEM for income and gains, IHTM42000 for inheritance tax), filed through different returns (SA900 for income and CGT, IHT100 for periodic and exit charges), and governed by different primary legislation.12 Practitioner guidance typically addresses these regimes in isolation, yet the accountant managing trust compliance must navigate all three simultaneously.

The urgency of an integrated approach has intensified. The abolition of the GBP 1,000 standard rate band from 6 April 2024 simplified income tax calculation but increased effective rates for trusts with modest income.3 The unified CGT rate of 24% from 30 October 2024 eliminated the residential/non-residential distinction but increased the non-residential rate by four percentage points.4 The residence-based IHT regime enacted from 6 April 2025 under the Finance Act 2025 replaced the domicile-based system for determining excluded property status, creating dynamic exposure that shifts with the settlor's long-term UK residence status.5 Looking forward, the dividend ordinary rate rises from 8.75% to 10.75% from April 2026, savings and property trust rates increase to 47% from April 2027, and trusts receive a dedicated GBP 2.5 million APR/BPR allowance from April 2026.67

This article consolidates the three charging regimes into a single practitioner resource. The structure proceeds from trust classification (the prerequisite for determining tax treatment) through income tax, CGT, and IHT, before synthesising the compliance framework. Worked numerical examples demonstrate cross-regime interactions that emerge only when the three regimes are considered together.

2. Trust Classification and Tax Consequences

2.1 The Classification Imperative

Trust classification determines the entire tax treatment across all three regimes. A misclassification does not produce a minor error -- it generates incorrect rates, wrong reporting obligations, and potentially incorrect IHT charges spanning a ten-year period. Four principal categories require differentiation.

Bare trusts are transparent: the beneficiary is assessed on income and gains as if the trust did not exist, with no separate income tax or CGT obligation falling on the trustees.1 However, bare trusts remain within the IHT framework where the property forms part of the beneficiary's estate for IHT purposes.

Interest in possession trusts (IIP) are taxed at the basic rate on non-dividend income (20%) and the dividend ordinary rate on dividend income (currently 8.75%, rising to 10.75% from April 2026).6 The beneficiary with the qualifying interest is assessable on the income and may reclaim any excess tax paid. For IHT, qualifying interests in possession created before 22 March 2006 remain within the estate of the life tenant under IHTA 1984 s 49(1), while post-March 2006 IIPs generally fall within the relevant property regime.8

Discretionary and accumulation trusts attract the highest income tax rates: 45% on non-dividend income and 39.35% on dividend income under ITA 2007 ss 479-481.9 For CGT, trustees pay 24% on all disposals. For IHT, these trusts form the core of the relevant property regime under IHTA 1984 ss 58-69, subject to periodic ten-year charges and proportionate exit charges.2

Privileged trusts escape the full relevant property regime. Bereaved minor trusts under IHTA 1984 s 71A are exempt from ten-year and exit charges.10 Age 18-to-25 trusts under s 71D attract exit charges only between ages 18 and 25, capped at 4.2%. Disabled person's trusts under s 89 are treated as if the beneficiary holds an interest in possession, with income tax and CGT eligible for the vulnerable beneficiary election under Finance Act 2005 Schedule 1A.10

2.2 Classification Reference Table

Trust Type Income Tax Rate (Non-Dividend) Income Tax Rate (Dividend) CGT Rate IHT Regime
Bare Beneficiary's marginal rate Beneficiary's marginal rate Beneficiary's rate Part of beneficiary's estate
IIP (pre-22/03/2006) 20% (basic rate) 8.75% (10.75% from Apr 2026) 24% (trustees) Life tenant's estate (s 49(1))
Discretionary/Accumulation 45% (trust rate) 39.35% (dividend trust rate) 24% (trustees) Relevant property regime (ss 58-69)
Bereaved minor (s 71A) 45% (trust rate) 39.35% 24% Exempt from periodic/exit charges
Disabled person's (s 89) Vulnerable beneficiary election available Election available Election available Treated as IIP

3. Income Tax: Rates, the Tax Pool, and Beneficiary Distributions

3.1 Current Rate Framework

Discretionary and accumulation trusts pay income tax at the trust rate of 45% on non-dividend income and the dividend trust rate of 39.35% on dividend income under ITA 2007 s 479.9 Since 6 April 2024, the former GBP 1,000 standard rate band (which taxed the first GBP 1,000 at basic rates) has been replaced by a simpler GBP 500 exemption: trusts with total income not exceeding GBP 500 pay no income tax.3 Where the same settlor has created multiple trusts, the GBP 500 threshold is shared equally with a minimum of GBP 100 per trust.

Trust management expenses remain deductible against income at the basic rate (20% for non-dividend income, 8.75% for dividend income) under ITA 2007 s 484, reducing the effective amount assessable at the trust rate.9

3.2 The Tax Pool: A Live Compliance Risk

The tax pool records cumulative tax paid by trustees on trust income. When trustees make discretionary distributions to beneficiaries, each distribution carries a deemed 45% tax credit regardless of the actual rate paid.11 This mechanism creates a structural problem for dividend income: trustees pay 39.35% dividend trust rate but must account for a 45% credit, producing a 5.65 percentage point shortfall on every pound of dividend income distributed.12

The practical consequence is that trusts with dividend-heavy investment portfolios deplete their tax pool faster than it accumulates. Trustees must fund the shortfall from tax paid on other income types (where 45% has been paid, creating a surplus relative to the 45% credit) or from trust capital. Accountants managing trust portfolios should monitor the tax pool balance annually to identify emerging deficits before they become critical.

Beneficiaries receive form R185 (Trust Income) showing the net distribution and the 45% tax credit. Basic-rate taxpayers can reclaim 25 percentage points (the difference between the 45% credit and their 20% liability), while higher-rate taxpayers reclaim 5 percentage points (45% minus 40%). Non-taxpayers and those within the personal allowance may reclaim the full 45% credit.11

3.3 Worked Example: Income Tax on Mixed Trust Income

Consider a discretionary trust receiving GBP 20,000 gross income in 2025-26: GBP 12,000 rental income and GBP 8,000 dividend income. Trust management expenses total GBP 1,500.

Step 1 -- Allocate management expenses. Under HMRC practice, expenses are allocated first against non-dividend income. GBP 1,500 of management expenses reduces the rental income taxable at the trust rate from GBP 12,000 to GBP 10,500 (with basic rate relief at 20% generating GBP 300 of relief at the trust rate differential).

Step 2 -- Calculate tax. Rental income: GBP 10,500 at 45% = GBP 4,725 (after basic rate relief adjustment). Dividend income: GBP 8,000 at 39.35% = GBP 3,148. Total trust tax: GBP 7,873.

Step 3 -- Tax pool impact. Tax entering the pool: GBP 7,873. If the full GBP 18,500 net income (after expenses) were distributed, the required 45% credit would be GBP 8,325. The deficit is GBP 452, attributable entirely to the dividend shortfall (GBP 8,000 x 5.65% = GBP 452).12

Step 4 -- Beneficiary position. A basic-rate beneficiary receiving a GBP 10,000 net distribution would be treated as receiving GBP 18,182 gross (GBP 10,000 / 0.55), with a 45% tax credit of GBP 8,182. The beneficiary's actual liability at 20% is GBP 3,636, generating a repayment of GBP 4,546.11

3.4 Forthcoming Rate Changes

From 6 April 2026, the dividend ordinary rate rises from 8.75% to 10.75%, directly increasing the income tax burden on interest in possession trusts holding dividend-paying investments.6 The dividend trust rate for discretionary trusts remains at 39.35%, leaving the structural tax pool deficit unchanged for these trusts.

From 6 April 2027, the trust rate for savings and property income rises to 47%, while the basic rate for these income types increases to 22%.6 This two-percentage-point increase widens the differential between trust and personal rates. If the deemed tax credit on discretionary distributions remains at 45%, trusts paying 47% on savings and property income would generate a structural overpayment in the tax pool for those income categories -- a reversal of the current dividend deficit problem. Practitioners should monitor whether the distribution credit mechanism is adjusted to align with the 47% rate.

4. Capital Gains Tax: The 24% Unified Rate and Holdover Relief

4.1 Current CGT Position

Trustees are treated as a single and continuing body of persons distinct from the individual trustees under TCGA 1992 s 69.13 From 30 October 2024, trustees pay CGT at a unified rate of 24% on all asset disposals, eliminating the previous distinction between residential property (28%) and other assets (20%).4 The annual exempt amount for 2025-26 is GBP 1,500, shared equally among trusts created by the same settlor with a minimum of GBP 300 per trust where five or more trusts exist. Trusts with vulnerable beneficiaries receive a GBP 3,000 annual exempt amount.4

UK property disposals by trustees trigger a 60-day reporting and payment obligation from the completion date, requiring accountants to ensure conveyancing timelines align with CGT compliance deadlines.

4.2 Holdover Relief: Deferral, Not Elimination

Holdover relief under TCGA 1992 s 260 is available on transfers into and out of relevant property trusts, allowing the transferor and transferee to jointly elect to defer the gain.14 The effect is that the transferee acquires the asset at the transferor's base cost, deferring the gain until the transferee ultimately disposes of the asset. This is a deferral mechanism, not an elimination -- a distinction frequently misunderstood in practice.

Holdover relief is not available for settlor-interested trusts, where the settlor or their spouse retains a benefit from the trust property.14 Settlor-interested trust status also triggers income attribution under ITA 2007 ss 624-628, making the settlor assessable on the trust income as if it were their own.

4.3 Worked Example: CGT Holdover on Transfer to Beneficiary

Trustees of a discretionary trust hold commercial property acquired in 2015 at GBP 200,000, now valued at GBP 500,000. The trustees transfer the property to a beneficiary in 2025-26.

Without holdover relief: Gain of GBP 300,000 less GBP 1,500 AEA = GBP 298,500 at 24% = GBP 71,640 CGT payable by trustees.4

With holdover relief (s 260 election): The gain is held over. The beneficiary acquires the property at the trustees' base cost of GBP 200,000. No CGT is payable on the transfer. However, when the beneficiary later sells the property for GBP 600,000, the chargeable gain is GBP 400,000 (GBP 600,000 minus GBP 200,000), not GBP 100,000. The deferred gain of GBP 300,000 crystallises alongside the beneficiary's own gain of GBP 100,000.14

The planning implication is that holdover relief is most advantageous where the beneficiary has unused annual exempt amounts, a lower marginal rate, or intends to hold the asset until death (when the gain is eliminated under the uplift to market value on death).

5. Inheritance Tax: The Relevant Property Regime

5.1 The Three-Charge Framework

The relevant property regime under IHTA 1984 ss 58-69 imposes three categories of IHT charge on discretionary trusts and most post-March 2006 trusts.2

Entry charge: Lifetime transfers into relevant property trusts are immediately chargeable at 20% (half the 40% death rate) on amounts exceeding the GBP 325,000 nil-rate band, which is frozen until 5 April 2031.15 The settlor's cumulative chargeable transfers in the seven years preceding the settlement reduce the available nil-rate band.

Ten-year anniversary charge (s 64): On each tenth anniversary of the trust's creation, a charge arises on the value of relevant property. The maximum rate is 6%, calculated as 30% of the effective rate on a hypothetical chargeable transfer under s 66.16 The effective rate is determined by constructing a notional transfer equal to the value of relevant property plus any amounts on which entry or exit charges have been levied in the preceding ten years plus the settlor's cumulative transfers at the date of settlement.

Exit charge (s 65): When property ceases to be relevant property between ten-year anniversaries (through distribution to beneficiaries or the creation of an interest in possession), a proportionate charge arises. Before the first ten-year anniversary, the rate under s 68 is calculated as 3/10 multiplied by N/40, where N is the number of complete quarters between commencement and exit. After a ten-year anniversary, s 69 applies the same fraction to the last-calculated ten-year rate.17

5.2 Worked Example: Ten-Year Anniversary Charge

A discretionary trust was created on 1 July 2016 with GBP 500,000 in cash. At the tenth anniversary on 1 July 2026, the trust holds assets valued at GBP 800,000. The settlor had made no other chargeable transfers prior to the settlement. No additions or exits have occurred.

Step 1 -- Construct hypothetical transfer. The hypothetical chargeable transfer under s 66 equals: trust value (GBP 800,000) plus any amounts on which charges have been levied in the preceding ten years (nil) = GBP 800,000. Add the settlor's cumulative transfers at settlement date (nil). Total: GBP 800,000.16

Step 2 -- Apply nil-rate band. GBP 800,000 less GBP 325,000 NRB = GBP 475,000 chargeable at the lifetime rate of 20%.

Step 3 -- Calculate hypothetical IHT. GBP 475,000 at 20% = GBP 95,000. Effective rate: GBP 95,000 / GBP 800,000 = 11.875%.

Step 4 -- Apply 30%. 30% of 11.875% = 3.5625%.

Step 5 -- Calculate charge. GBP 800,000 at 3.5625% = GBP 28,500.16

If the trust held GBP 3 million of qualifying agricultural property at the tenth anniversary falling on or after 6 April 2026, the GBP 2.5 million APR/BPR trust allowance would apply: GBP 2.5 million at 100% relief and GBP 500,000 at 50% relief, leaving GBP 250,000 as the chargeable value for the periodic charge calculation. The trust allowance refreshes every ten years, aligned with the anniversary cycle.7

5.3 The Residence-Based IHT Regime and Trust Exposure

From 6 April 2025, the excluded property status of trust assets depends on the settlor's long-term UK residence (LTR) status at the time of a chargeable event, not at the date of settlement.5 This creates a dynamic exposure: non-UK assets held in trust are excluded from IHT while the settlor is not long-term UK resident (broadly, resident for fewer than 10 of the preceding 20 tax years). If the settlor subsequently becomes LTR, those non-UK assets become chargeable to the periodic and exit charge regime.

Transitional provisions apply to non-UK assets settled before 30 October 2024: these assets are not subject to gift-with-reservation provisions, but they fall within the relevant property charges once the settlor becomes LTR.5 Accountants managing trusts with international dimensions must implement ongoing monitoring of the settlor's residence position, reassessing excluded property status at each ten-year anniversary and before any proposed distribution. The three-to-ten-year "tail" provisions mean that a formerly LTR individual departing the UK remains within the IHT framework for a minimum of three years, extending to ten years for individuals who were UK-resident for 20 or more years.18

6. Compliance Framework: SA900, Trust Registration Service, and AEOI

6.1 SA900 Filing Obligations

Trustees must file a Trust and Estate Tax Return (SA900) where the trust has taxable income or chargeable gains.19 Filing deadlines for the 2025-26 tax year are 31 October 2026 (paper return or where HMRC is to calculate tax) and 31 January 2027 (online filing). Late filing incurs an automatic GBP 100 penalty, with further daily penalties for persistent default.19

Trusts with total income not exceeding GBP 500 may not need to file where all income tax has been satisfied at source. Supplementary forms are required for specific income types: trade income, foreign income, and capital gains each require separate supplementary pages. The SA950 Trust and Estate Tax Return Guide provides detailed completion instructions.20

6.2 Trust Registration Service

All UK express trusts must register on the Trust Registration Service (TRS) unless specifically excluded under TRSM22010.21 Taxable trusts created after 5 April 2021 must register within 90 days. Non-taxable trusts must register within 90 days of becoming registrable. Trust information must be kept updated within 90 days of any changes to the trust's beneficial ownership, assets, or administration.

6.3 AEOI Registration: The 2025 Deadline

The International Tax Compliance (Amendment) Regulations 2025 introduced additional automatic exchange of information (AEOI) obligations for trusts qualifying as reporting financial institutions.22 The qualifying test is whether 50% or more of the trust's income derives from investments managed by a discretionary fund manager. Trusts meeting this threshold were required to register for AEOI by 31 December 2025, with penalties of up to GBP 1,000 plus GBP 300 per day for failure to register. For reporting failures, penalties escalate to GBP 5,000 plus GBP 600 per day.

From 1 January 2026, expanded Common Reporting Standard obligations include cryptoasset transactions under the Crypto-Asset Reporting Framework (CARF), extending the reporting scope for trusts holding digital assets.22

Trusts that missed the 31 December 2025 registration deadline should register immediately and consider whether a reasonable excuse defence is available. HMRC's approach to late registrations in this first compliance period remains to be determined.

6.4 Annual Compliance Calendar

Accountants managing multiple trusts benefit from a structured annual compliance timeline:

  • Within 60 days of UK property disposal: CGT reporting and payment
  • Within 90 days of trust changes: TRS update
  • 5 October: Notify HMRC of new trust requiring SA900 registration
  • 31 October: SA900 paper filing deadline
  • 31 January: SA900 online filing deadline and payment of income tax and CGT
  • 6 months after ten-year anniversary or exit event: IHT100 filing and payment for periodic and exit charges
  • Annually: AEOI reporting for qualifying trusts; tax pool reconciliation

Conclusion

The three charging regimes governing trust taxation -- income tax under ITA 2007 Part 9, CGT under TCGA 1992, and IHT under IHTA 1984 ss 58-69 -- are not three separate compliance problems but one integrated challenge. Decisions in each regime generate downstream consequences in the others: a holdover relief election that defers CGT crystallises a larger gain on the beneficiary's eventual disposal; a discretionary distribution that depletes the tax pool also triggers an IHT exit charge reducing the trust fund available for the ten-year anniversary; an asset allocation favouring dividends reduces income tax below the trust rate but creates structural tax pool deficits.

The forthcoming rate changes amplify these interactions. The April 2026 dividend ordinary rate increase to 10.75% raises the cost of holding dividend-paying investments within IIP trusts. The April 2027 savings and property trust rate increase to 47% fundamentally alters the cost-benefit analysis for trusts holding investment property or cash deposits, widening the differential between trust and higher personal rates to 5 percentage points for these income types (47% trust rate versus 42% higher rate), though the trust rate matches the personal additional rate (also 47%).6 From April 2027, pension death benefits enter the IHT charge, affecting overall estate calculations where trust-based planning interacts with pension fund nominations.23

The GBP 2.5 million APR/BPR trust allowance from April 2026 introduces a new variable into the ten-year charge calculation for trusts holding qualifying business or agricultural property, while the residence-based IHT regime from April 2025 creates ongoing monitoring obligations for trusts with non-UK assets.57 Accountants who treat trust taxation as three parallel streams, rather than one interconnected system, risk advisory errors that compound across regimes and across the trust's lifetime.

CPD Declaration

Estimated Reading Time: 22 minutes Technical Level: Advanced Practice Areas: Trust Taxation, Income Tax Compliance, Inheritance Tax, Capital Gains Tax

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Classify trusts into the four principal categories (bare, interest in possession, discretionary, privileged) and identify the income tax, CGT, and IHT consequences for each
  2. Calculate the tax pool position for a discretionary trust receiving mixed income, identifying the structural shortfall arising from dividend income taxed at 39.35% against a 45% deemed credit
  3. Apply the ten-year anniversary charge calculation under IHTA 1984 ss 64-66, including the hypothetical chargeable transfer, effective rate derivation, and 30% reduction
  4. Evaluate how the April 2026 and April 2027 rate changes alter the cost-benefit analysis for trust income accumulation versus distribution strategies

ICAEW/CIOT Competency Mapping

  • Tax compliance: Trust taxation compliance across income tax, CGT, and IHT regimes, including SA900 filing and trust registration obligations
  • Technical analysis: Multi-regime modelling of trust income, gains, and periodic/exit charges with integration of forthcoming rate changes

Reflective Questions

  1. How would the April 2027 increase in savings and property trust rates to 47% affect current recommendations regarding trust investment allocation between dividend, savings, and property income?
  2. What monitoring procedures should be implemented to track the tax pool balance for trusts with predominantly dividend income, and at what deficit threshold should distribution strategies be reconsidered?
  3. How might the dynamic excluded property status under the residence-based IHT regime change the frequency and scope of trust reviews for clients with international connections?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 24 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. GOV.UK -- Trusts and Taxes (2025). https://www.gov.uk/trusts-taxes ↩ ↩2

  2. IHTM42000 -- Relevant property trusts: contents. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm42000 ↩ ↩2 ↩3

  3. ITA 2007 s 484(3) -- omitted from 6 April 2024 by Finance (No. 2) Act 2023. https://www.legislation.gov.uk/ukpga/2007/3/section/484 ↩ ↩2

  4. GOV.UK -- Capital Gains Tax rates and allowances (2025-26). https://www.gov.uk/guidance/capital-gains-tax-rates-and-allowances ↩ ↩2 ↩3 ↩4

  5. Finance Act 2025, Part 2 Chapter 4 -- Inheritance Tax (residence-based regime). https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4/enacted ↩ ↩2 ↩3 ↩4

  6. HMRC Trusts and Estates Newsletter: February 2026. https://www.gov.uk/government/publications/hm-revenue-and-customs-trusts-and-estates-newsletters/hmrc-trusts-and-estates-newsletter-february-2026 ↩ ↩2 ↩3 ↩4 ↩5

  7. GOV.UK -- Reforms to IHT APR and BPR: application in relation to trusts -- Summary of responses (June 2025). https://www.gov.uk/government/consultations/reforms-to-inheritance-tax-reliefs-consultation-on-property-settled-into-trust/outcome/reforms-to-inheritance-tax-agricultural-property-relief-and-business-property-relief-application-in-relation-to-trusts-summary-of-responses ↩ ↩2 ↩3

  8. IHTA 1984 s 49(1) -- Treatment of interests in possession. https://www.legislation.gov.uk/ukpga/1984/51/section/49 ↩

  9. ITA 2007 s 479 -- Trustees' accumulated or discretionary income charged at special rates. https://www.legislation.gov.uk/ukpga/2007/3/section/479 ↩ ↩2 ↩3

  10. IHTA 1984 s 71A -- Trusts for bereaved minors; IHTA 1984 s 89 -- Trusts for disabled persons. https://www.legislation.gov.uk/ukpga/1984/51/section/71A ↩ ↩2

  11. TSEM3360 -- Trust income and gains: trust tax pool. https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem3360 ↩ ↩2 ↩3

  12. Quilter -- Taxation of income in discretionary trusts (April 2025). https://www.quilter.com/help-and-support/technical-insights/technical-insights-articles/taxation-of-income-in-discretionary-trusts/ ↩ ↩2

  13. TCGA 1992 s 69 -- Trustees treated as a single and continuing body. https://www.legislation.gov.uk/ukpga/1992/12/section/69 ↩

  14. TCGA 1992 s 260 -- Gifts on which IHT is chargeable (holdover relief). https://www.legislation.gov.uk/ukpga/1992/12/section/260 ↩ ↩2 ↩3

  15. IHTA 1984 Part III -- Settled Property; IHTM42001. https://www.legislation.gov.uk/ukpga/1984/51/part/III ↩

  16. IHTA 1984 s 64 -- Charge at ten-year anniversary; IHTA 1984 s 66 -- Rate of ten-yearly charge. https://www.legislation.gov.uk/ukpga/1984/51/section/64 ↩ ↩2 ↩3

  17. IHTA 1984 s 65 -- Charge at other times; IHTA 1984 s 68 -- Rate before first ten-year anniversary. https://www.legislation.gov.uk/ukpga/1984/51/section/65 ↩

  18. IHTM47000 -- Long-term UK residence: contents. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47000 ↩

  19. GOV.UK -- Self Assessment: Trust and Estate Tax Return (SA900). https://www.gov.uk/government/publications/self-assessment-trust-and-estate-tax-return-sa900 ↩ ↩2

  20. SA950 -- Trust and Estate Tax Return Guide 2025. https://assets.publishing.service.gov.uk/media/692700c99c1eda2cdf0340bd/SA950-2025.pdf ↩

  21. TRSM22010 -- Types of trust that need to be registered. https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm22010 ↩

  22. ICAEW -- Trusts must meet new registration requirement by 31 December (December 2025). https://www.icaew.com/insights/tax-news/2025/dec-2025/trusts-must-meet-new-registration-requirement-by-31-december ↩ ↩2

  23. GOV.UK -- Budget 2025: Overview of Tax Legislation and Rates (OOTLAR). https://www.gov.uk/government/publications/budget-2025-overview-of-tax-legislation-and-rates-ootlar/budget-2025-overview-of-tax-legislation-and-rates-ootlar ↩

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