Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Characterisation definition

What does Characterisation mean? In nuclear regulation and decommissioning practice, characterisation means the systematic identification, measurement and recording of the nature, quantity and properties of nuclear material and radioactive waste, and the determination of the detailed state and condition of a nuclear site (including radiological, chemical and physical aspects). It provides the evidence base for safety cases, decommissioning and remediation strategies, environmental permits, transport classification, waste acceptance, and nuclear material accountancy and safeguards reporting. The term is descriptive and widely used in regulatory guidance, licence conditions and permit requirements rather than being expressly defined in primary legislation or case law. Nevertheless, characterisation duties...

UK tax treatment of trust distributions: source and character rules (Baker/Garland), discretionary v life interest, ESC B18, dividend treatment, minor child attribution, and FIG regime from April 2025

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Practice notes

The way a distribution from a trust is taxed in the hands of the recipient turns first on whether it is income or capital.

Fixed interest trusts (life interest trusts)

In a fixed interest trust, one or more of the beneficiaries are entitled to receive the trust’s income as of right for a specified period or term. Where the arrangement is a life interest trust, the beneficiary, or life tenant, enjoys an absolute entitlement to the trust’s underlying income; that entitlement is known as an interest in possession. By comparison, within a discretionary trust the trustees have the power to decide whether, when and how much income to distribute to the beneficiaries from time to time. These distinctions are significant because they point to the source from which the income arises in each case. Identifying the source is important because it fixes the tax character of any distribution made by the trust for the recipient. For a fixed interest trust, the source of the income is the income‑producing assets themselves. Conversely, in a discretionary trust the trust itself is treated as the source of the income.

Source of income—life interest trusts

A leading case in defining the source of trust income...

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Web page updated on 21/05/2026

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