‘Relevant trustees’ are defined as follows ( TMA 1970, s. 7(9) , 118(1) ):

for the purpose of trust income, any person who was a trustee at or after the time when the income arose; or

for the purpose of trust gains, any person who was a trustee during or after the tax year in which the gain accrued.

The relevant trustees are made liable for certain payments of tax, surcharges, interest, and penalties ( TMA 1970, s. 107A ). These amounts may be recovered from any one or more of the trustees, though there are restrictions on the liability of particular trustees (see below).

Payment of tax

The following may be recovered from any relevant trustee ( TMA 1970, s. 107A(2)(b) ):

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