TSEM8520 - Trust management expenses: settlor-interested trusts: IIP trust
The settlor of a 바카라 사이트˜settlor-interested바카라 사이트™ IIP trust gets no relief for TMEs. In ITTOIA/S624 바카라 사이트˜income which arises under a settlement바카라 사이트™ in a settlor-interested trust is the income arising to the trustees, that is, the gross income before the trustees pay trust management expenses.
This applies whether or not the settlor is a beneficiary of an IIP trust. If the settlor is also the IIP beneficiary, ITTOIA/S624 deems all the income arising to the trustees to be the settlor바카라 사이트™s, and does not explicitly restrict the charge to that part of the trustees바카라 사이트™ income which does not already belong to the settlor in general law (the trust management expenses).