TSEM8135 - Trust management expenses: ‘properly chargeable to income� in general trust law: HMRC v Peter Clay: ‘the income beneficiaries�
While the Clay case was about accumulation/discretionary trusts, it covers trust management expenses in general trust law, and as such applies to interest in possession trusts too. So by ‘income beneficiaries� is meant discretionary income beneficiaries and IIP beneficiaries.