Non-UK Trust - Distributions to beneficiaries

[GL]

Dear All

An Non-UK Discretionary Trust (Non-settlor interested - the settlor who was always non-UK resident/non-domiciled) and the trustees are non-UK as well.

Beneficiaries are all UK res/Ord Res and domiciled.

If the trust is to be brought to and end and funds distributed to the beneficiaries, is the following correct:

Intial Capital of fund - Non Taxable
Income accumulated in the fund - Taxable on the beneficiaries as 'Other income' at their highest marginal rate
Gains accumulated in the fund - Taxable as Capital Gains

Any comments will be greatfully received