Statement of Practice 8 (1986)
Published 10 November 1986
© Crown copyright 1986
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This statement sets out the Commissioners for HM Revenue and Customs (HMRC) practice concerning the Inheritance Tax/Capital Transfer Tax treatment of income of discretionary trusts.
The Commissioners for HMRC take the view that:
- undistributed and unaccumulated income should not be treated as a taxable trust asset
- for the purpose of determining the rate of charge on accumulated income, the income should be treated as becoming a taxable asset of the trust on the date when the accumulation is made
This practice applies from 10 November 1986 to all new cases and to existing cases where the tax liability has not been settled.