TSEM8135 - Trust management expenses: 鈥榩roperly chargeable to income鈥� in general trust law: HMRC v Peter Clay: 鈥榯he income beneficiaries鈥�
While the Clay case was about accumulation/discretionary trusts, it covers trust management expenses in general trust law, and as such applies to interest in possession trusts too. So by 鈥榠ncome beneficiaries鈥� is meant discretionary income beneficiaries and IIP beneficiaries.