Revenue Precedent

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Revenue Precedents

Where the trustees of a trust are resident in the State but the whole of the trust income is payable to a beneficiary with an absolute interest in the assets of the trust who is not resident in the State or divisible between two or more beneficiaries, none of whom is resident here, the liability is confined to income arising here, subject to any exemption on the basis that the beneficiary is resident in a treaty country. IT912023