Trustees - extent of charge
06/12/1991
Query
Extent of charge where beneficiaries, with an absolute interest in the assets which are subject to the trust. are not resident in the State
Decision
Where the trustees of a trust are resident in the State but the whole of the trust income is payable to a beneficiary with an absolute interest in the assets of the trust who is not resident in the State or divisible between two or more beneficiaries, none of whom is resident here, the liability is confined to income arising here, subject to any exemption on the basis that the beneficiary is resident in a treaty country.
Income Tax
Section 1046, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:IT912023