A claim for an income tax credit under ESC B18 was not limited to income which arose up to six years before the end of the tax year in which the payment to the beneficiary was made. 

Summary 

A claim for income tax credit under Extra Statutory Concession (ESC) B18 was not limited to income which arose up to six years before the end of the tax year in which the payment to the beneficiary was made. 

Background 

The UK resident appellants were the beneficiaries of a discretionary trust resident for UK tax purposes in Guernsey. The trustees received UK source income in the form of interest, on which UK income tax was paid. The net amounts generated further income as overseas bank interest. 

In September 2018, a firm of accountants (M) wrote to HM Revenue and Customs (HMRC) on behalf of the appellants and trustees, asking for confirmation that ESC B18 would apply to