TSEM3474 - Trust income and gains: vulnerable beneficiaries: claims to special tax treatment: computing the amount of relief: income tax - basic example

A trust has arisen in England as a result of an intestacy. There is one current beneficiary, a UK resident minor who is a vulnerable person. Because of the right to accumulate the trustees are liable at the special trust rates. A valid vulnerable beneficiary election is in force. The trustees receive the following income in 2019-20:

Income Amount

Rent

£20,000

Bank interest

£5,000

UK dividends

£10,000

TQTI (the trustees’ tax liability before making a claim for special tax treatment) is:

Tax Rates

Non-savings

Savings

Dividend

Total

Income

£20,000

£5,000

£10,000

-

Tax at standard rate 20%

£1,000

-

-

-

Tax at Trust rate 45%

£19,000 £5,000

-

-

Tax at Trust dividend rate 38.1% - - £10,000 -

Tax chargeable

£8,750.00

£2,250.00

£3,810.00

£14,810.00

The vulnerable person has no personal income or gains in the year and so the amount of TLV2 is nil.

TLV1 (the amount of additional tax that the vulnerable person would pay if the qualifying trusts income arose directly to him or her) is:

Income

Non-savings

Savings

Dividend

Total

Income - actual

-

-

-

-

Income treated as arising to the vulnerable person

£20,000

£5,000

£10,000

-

-

£20,000

£5,000

£10,000

-

Less personal allowance

£12,500

-

-

-

Savings chargeable after £1,000 allowance (20%)

-

£4,000

-

-

Tax chargeable

-

£800.00

-

£800.00

Chargeable at dividend rate after £2,000 dividend allowance (7.5%)

-

-

£8,000

-

Tax chargeable

-

-

£600.00

£600.00

Chargeable at lower rate (20%)

£7,500

-

-

-

Tax chargeable

£1,500.00

-

-

£1,500.00

TLV1

-

-

-

£2,900.00

Less TLV2

-

-

-

£0.00

VQTI

-

-

-

£2,900.00

The reduction that the trustees can claim is TQTI - VQTI (£14,810 - £2,900) = £11,910. Their final liability is therefore:

Tax Due Total

Tax due

£14,810.00

Less reduction for special tax treatment

£11,910.00

-

£2,900.00


The trustees must also ensure that they have paid enough income tax to cover the deemed deduction of tax on the distribution to the beneficiary (see TSEM3490).