Until 2012–13, a trustee having the direction, control or management of property held on bare trusts (see ¶350-575) for a beneficiary who was a minor or a mentally handicapped person was assessable and chargeable to income tax in respect of income arising from that property. The quantum of the liability was calculated as if the income arose directly to the beneficiary himself and no regard was taken of the personal circumstances of the individual trustee. It was thus possible for the trustee to claim repayment of income tax by reference to the personal allowance available to the beneficiary.

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