by GF2 on Thu May 05, 2011 2:08 pm
A had a discretionary trust drawn up last year and transferred £325K into it. A is a trustee. A is not a beneficiary. The trust has invested the money in rental properties.
A would now like to lend the trust additional capital for it to buy more properties.
The objective is to allow the trust to generate additional income/ achieve capital growth outside of A's estate.
1) Are there restrictions on how much/ little interest the trust can pay to A on the loan?
2) I assume the trust can deduct any interest payments from the income it receives for the purposes of calculating its tax.
3) I assume A declares any interest they receive from the trust as income on A's personal tax return.
Are there any issues that need to be considered to avoid it being preceived that A is exceeding the £325K limit or conversely benefiting from the trust?
Many thanks for any clarification you can offer!