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Trust Taxation Reference

What this page covers

A trust pays the highest flat rate in the system, but income distributed to a beneficiary in the same year is taxed in that person's hands instead. The difference between those two outcomes is most of trust planning.

45%flat trust rate
80%CGT inclusion
36%effective CGT
8.25%official rate, s7C
Rates that apply to a trust
ItemTrustIndividual, top bracketCompany
Income tax rate45%45%27%
CGT inclusion rate80%40%80%
Effective CGT rate36%18%21.6%
Annual CGT exclusionNoneR50,000None
Interest exemptionNoneR23,800None
Where the income is taxed
SituationTaxed in the hands of
Income distributed to a resident beneficiary in the same yearThe beneficiary, at their rate
Income retained in the trustThe trust, at 45%
Income from assets donated by a living donorThe donor, under attribution
Income of a special trust for a disabled personAt individual rates
Capital gain distributed in the same yearThe beneficiary, at their inclusion rate
Section 7C, the interest-free loan rule
ItemRule
What it targetsAn interest-free or low-interest loan to a trust
Deemed donationThe shortfall against the official rate of interest
Official rate8.25%
Donations tax20% on the deemed donation above the annual exemption
Annual donations exemptionR150,000 for a natural person

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How these figures work

The figures on this page come from the body that publishes them and change on a schedule rather than continuously, which is what makes them worth keeping in one place. A trust is rarely a tax saving on its own. Its value is in estate planning and asset protection, and the 45% rate is the price of leaving income inside it.

The conduit principle only works for income vested in a beneficiary in the same tax year it arises. Vest it late and the trust pays.

★ What this means in practice

Budget 2026 announced no changes to the taxation of trusts.

✕ Common mistakes

  • A trust is rarely a tax saving on its own. A trust is rarely a tax saving on its own. Its value is in estate planning and asset protection, and the 45% rate is the price of leaving income inside it.
  • The conduit principle only works for income vested in a beneficiary in t. The conduit principle only works for income vested in a beneficiary in the same tax year it arises. Vest it late and the trust pays.
  • Budget 2026 announced no changes to the taxation of trusts. Budget 2026 announced no changes to the taxation of trusts.
  • Taking a figure without its date. A number from a reference page is only as good as when it was last checked, which is why the date sits at the top of this one.

Notes on reading these figures

  • A trust is rarely a tax saving on its own. Its value is in estate planning and asset protection, and the 45% rate is the price of leaving income inside it.
  • The conduit principle only works for income vested in a beneficiary in the same tax year it arises. Vest it late and the trust pays.
  • Budget 2026 announced no changes to the taxation of trusts.

To put these figures to work, The Company Tax Rates Reference runs the arithmetic on your own numbers; Capital Gains Tax Rates and Exclusions covers the same ground in ordinary language; Estate Duty and Donations Tax goes into the detail this table only summarises; Estate Duty Calculator is the related figure worth reading beside it; and Trading through a company covers what this page leaves out.

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Terms used on this page

Definitions
Conduit principle
Income vested in a beneficiary in the same year is taxed in their hands.
Attribution
Income from donated assets taxed in the donor's hands.
Section 7C
Deems a donation where a loan to a trust carries below the official rate.
Special trust
A trust for a disabled person, taxed at individual rates.
Vesting
Making income or a gain the beneficiary's entitlement in that year.

Frequently asked questions

Why is the trust rate so high?

45% is deliberate. It removes any incentive to leave income in a trust rather than distribute it, which is what the conduit principle is designed to encourage.

How does the conduit principle work?

Income vested in a resident beneficiary in the same tax year it arises is taxed in that person's hands at their rate, not in the trust.

What is section 7C?

It deems a donation where you lend money to a trust at below the official rate of interest, currently 8.25%. The shortfall attracts donations tax.

Is a trust a tax saving?

Rarely on its own. Its value is in estate planning and asset protection, and 45% is the price of that structure.

What is the CGT position?

A trust includes 80% of a gain against an individual's 40%, giving an effective 36% against 18%.

Did Budget 2026 change trust taxation?

No changes to the taxation of trusts were announced.