TSEM3759 - Trust income and gains: individual beneficiary receives discretionary payment from a resident trust: when payment made
For tax purposes the beneficiary receives a payment on:
- The date the trustees made the payment or
- The date the beneficiary became legally entitled to require the trustees to pay over the income. This could be when the payment indefeasibly vested, following the trustees’ resolution.
Cunard’s Trustees v CIR 27 TC 122