TSEM8410 - Trust management expenses: bare trusts: exception
Exceptionally, the trustees may have, as a matter of statute law, a charge, lien or other right to resort to the assets (for example for the payment of Estate Duty, Capital Transfer Tax, Inheritance Tax, Capital Gains Tax etc).
If the trustees have a statutory lien over the funds held on bare trust, then because the fund cannot be said to be absolutely the beneficiary바카라 사이트檚, the position reverts to something like an IIP trust. Although in a bare trust there is no concept of 바카라 사이트榩roperly chargeable to income바카라 사이트�, in these circumstances those expenses which would be properly chargeable to income in an IIP trust will be treated as 바카라 사이트榩roperly chargeable to income바카라 사이트�.
So for the purposes of higher rate tax, and only as long as the lien etc. exists, the expenses that the trustees incur, that are properly payable out of income reduce the income that the beneficiary declares.