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Statutory Trust Rules · Finance Act 2024 s.23 & ITA 2007

Trust Taxation & 10-Year Charge Calculator (2026/27)

Calculate trustee Income Tax liabilities across discretionary, interest in possession, and bare trusts. Model the £500 de minimis exemption, allowable Trust Management Expenses (TME), beneficiary Form R185 tax credits, tax pool balances, and 10-year anniversary periodic IHT charges.

Finance Act 2024 · ITA 2007 s.479-498 · IHTA 1984 s.64

UK Trust Taxation & 10-Year Charge Calculator

Model trustee income tax liabilities under the 45% trust rate and 39.35% dividend rate, apply the £500 de minimis exemption, calculate R185 tax credits, and estimate 10-year anniversary periodic IHT charges.

Common Trust Scenarios:
De Minimis: £500

Under Finance Act 2024, the £500 de minimis is divided equally among all active trusts created by the settlor (with a statutory floor of £100 per trust).

Trust Annual Income (2026/27)

£
Taxed at 45% (trust rate) in discretionary trusts; 20% in IIP trusts.
£
Taxed at 39.35% (dividend trust rate) in discretionary trusts; 8.75% in IIP.
£
Section 484 ITA 2007: Expenses properly incurred in income management.

Distributions & 10-Year IHT Parameters

Beneficiary Income Distribution & R18545% Tax Credit
10-Year Anniversary IHT Periodic ChargeMax 6% Rate

Total income exceeds the £500 de minimis threshold. Therefore, under HMRC legislation, the full income is subject to trust rates (45% on non-dividend, 39.35% on dividend income).

Total Trustee Income Tax (2026/27)Effective: 39.8%
£13,918.75
Non-Dividend Tax (45%)
£9,000.00
Dividend Tax (39.35%)
£4,918.75
Gross Trust Income£35,000.00
Allowable Trust Expenses (TME offset)-£2,500.00
Net Taxable Trust Income£32,500.00
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How UK Trust Taxation Works in 2026/27

Trusts in the United Kingdom operate under distinct statutory tax regimes governed primarily by the Income Tax Act 2007 (ITA 2007), the Inheritance Tax Act 1984 (IHTA 1984), and significant modernization measures enacted under the Finance Act 2024.

Unlike individuals, discretionary trusts do not benefit from a personal allowance or dividend allowance. Instead, income is taxed at the highest statutory rates to prevent wealthy individuals from using trusts to shelter income from personal taxation.

UK Trust Rates by Classification (2026/27)

Trust TypeNon-Dividend RateDividend RateDe Minimis Threshold
Discretionary / Accumulation45% (Trust Rate)39.35% (Div Trust Rate)£500 (FA 2024)
Interest in Possession (IIP)20% (Basic Rate)8.75% (Ordinary Rate)N/A (Life tenant taxed)
Bare Trust0% (Trustee level)0% (Trustee level)Taxed on Beneficiary

The Finance Act 2024 £500 De Minimis Exemption

From 6 April 2024, Section 23 of the Finance Act 2024 abolished the old £1,000 standard rate band and established a statutory £500 de minimis threshold:

  • Below or Equal to £500:If the trust's total taxable income does not exceed £500, no Income Tax is due from the trustees. Trustees are not required to submit an SA900 trust return for this income.
  • Exceeding £500: If total income is £501 or more, the entire income is chargeable at trust rates (45% or 39.35%). The £500 does not function as a nil-rate band.
  • Multiple Trusts Rule: Where a settlor has created more than one active settlement, the £500 de minimis is divided equally among the active trusts, subject to a statutory minimum floor of £100 per trust.

Beneficiary Distributions & Form R185 Tax Credits

When discretionary trustees distribute income to a beneficiary, the payment is treated as having suffered 45% Income Tax. For example, a £5,500 net distribution represents £10,000 of gross trust income carrying a £4,500 non-repayable tax credit.

Trustees provide the beneficiary with HMRC Form R185 (Trust Income). If the beneficiary is a non-taxpayer or basic-rate taxpayer, they can submit an SA100 or Form R40 repayment claim to HMRC, recovering up to 45% of the gross income as a cash refund!

The 10-Year Anniversary Inheritance Tax (IHT) Charge

Discretionary trusts are categorized as relevant property under the Inheritance Tax Act 1984. Every 10 years from the date the trust was created, the trustees must value all trust assets and calculate the 10-year periodic charge:

  • Assets up to the available Nil-Rate Band (£325,000) are exempt.
  • The available nil-rate band is reduced by chargeable transfers made by the settlor in the 7 years before creating the trust.
  • The statutory maximum periodic charge is 6.0% (calculated as 30% of the 20% lifetime IHT rate).
  • Exit charges (Section 68 IHTA 1984) apply when capital is distributed between 10-year milestones, calculated in 40ths based on completed calendar quarters.

Primary Statutory Authorities:

Published by AfterTaxUK Editorial Team · Reviewed 26 October 2026. This calculator provides illustrative statutory calculations. Trust taxation involves complex anti-avoidance legislation (settlor-interested trusts, parental settlement rules). Consult an STEP-accredited trust and estate practitioner.

Frequently Asked Questions

Clear answers based on official HMRC rules and statutory guidance.

For the 2026/27 tax year, UK discretionary and accumulation trusts are taxed under Section 479 of the Income Tax Act 2007 (ITA 2007) at the trust rate of 45% on non-dividend income (such as commercial/residential rental profits, trading income, and savings interest) and at the dividend trust rate of 39.35% on dividend income. For Interest in Possession (life interest) trusts, trustees pay basic rate Income Tax at 20% on non-dividend income and 8.75% ordinary rate on dividends.

The trust type changes the rules

Bare, interest-in-possession and discretionary trusts do not share one universal income-tax calculation. Establish the deed, beneficiary rights and type of income.

Trustee tax, beneficiary credits, the tax pool, capital gains and Inheritance Tax charges are separate. This estimate is not a complete trust account or a determination of the trust classification.

Check the rules for your circumstances

Official guidance supports the rules described here; it does not approve or certify this calculator. Confirm dates, eligibility and unsupported cases before making a financial decision.