Corporation Tax Act 2010 section 621

Treatment of income

Section 621 establishes how income arising within an exempt unauthorised unit trust is treated for corporation tax purposes, clarifying that the income belongs to the trustees rather than to the individual unit holders.

• Income arising to the trustees of an exempt unauthorised unit trust is treated as the trustees' own income for corporation tax purposes.
• The income is not treated as the income of the unit holders, even though they are the beneficial owners of the trust.
• This rule ensures that the taxation of trust income is dealt with at the trustee level rather than being attributed to each individual unit holder.
• A corresponding income tax rule exists separately, so this section applies specifically within the corporation tax framework.