My UK resident client is the main beneficiary of a non-UK resident trust. The trust historically held an apartment in London since its creation in 2008, which it sold in 2019-20 at a large gain.

Since then, the trust has just held cash, which it is looking to partially distribute to my client in the next few weeks, and I would like to understand the tax implications of the transfer for my client?

Where a UK resident beneficiary of a non-UK resident trust receives a capital payment, the beneficiary can be chargeable on: