TSEM3755B – Trust income and
gains: company beneficiary receives discretionary payment from a
resident trust
ICTA/Section 687A deals with discretionary payments by trustees
to companies. Where the company is chargeable to corporation tax,
and is not a charity, a heritage body or a scientific research
organisation.
- payments are left out of account in
calculating the profits of the company for CT purposes;
- no set-off of income tax credit under
ITA/S494 is allowed against the company’s CT Or income tax
payable by it;
- no repayment is to be made to the company
in respect of the amount treated as paid by the recipient under
ITA/S494.
