Does a bare trust get top-slicing relief?

Yes. Under a bare trust the beneficiary is treated as the individual liable for the gain, so an individual beneficiary can claim top-slicing relief on their own income and allowances, just as if they held the bond directly.

Do personal representatives get top-slicing relief?

No. Where personal representatives are assessed on a chargeable event gain — for example a bond continuing after the policyholder’s death — the gain is charged at the basic rate with no top-slicing relief.

Why does it matter who holds the bond?

Because the relief follows the person liable for the gain. The same gain can attract substantial top-slicing relief for an individual and none at all for a discretionary trust — so the ownership structure changes the tax, not just the paperwork.

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Can trustees claim top-slicing relief?

Top-slicing relief is given to individuals. When a discretionary trust is the person liable for a bond gain, the relief simply isn’t there. The same gain, taxed differently.

Based on ITTOIA 2005 ss.465–467 and s.535, and HMRC’s Insurance Policyholder Taxation Manual — IPTM3250 (“person liable to charge: summary of the position in relation to trusts”) for the trust cases and IPTM3240 (“person liable to charge: death cases”) for the personal-representative case this article also covers.

4 min read · Last reviewed 16 Jun 2026

— In short

Generally no. Top-slicing relief is an individual's relief under ITTOIA 2005 s.535, so where trustees of a discretionary or other non-bare trust are the person liable for a bond gain, the gain is taxed at the trust rate with no relief. A bare trust is the exception: the beneficiary is treated as the individual liable and can claim. Personal representatives assessed on a gain are charged at the basic rate with no relief either.

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Generally, no. Top-slicing relief is an individual'srelief — ITTOIA 2005 s.535 gives it to “an individual” liable to income tax on a chargeable event gain. Where the person liable for the gain is the trustees of a discretionary (non-bare) trust, the relief is not available. The bare-trust case is the exception.

Who is “liable” matters

Top-slicing relief follows the person chargeable to tax on the gain, and the chargeable-event rules set out who that is (ITTOIA 2005 ss.465–467):

Top-slicing relief by who is liable for the gain (ITTOIA 2005 ss.465–467; IPTM3250 trusts, IPTM3240 death cases)

An individual (incl. as bare-trust beneficiary): Relief available
Trustees of a discretionary / non-bare trust: No relief
Personal representatives of an estate: No relief
Bare trust: Beneficiary is the individual — relief available

Where UK trusteesof a discretionary settlement are liable (s.467), the gain is taxed at the trust rate with no top-slicing relief. The relief is computed by reference to an individual's income and allowances, which a trust doesn't have. A bare trust is different: the beneficiary is treated as the person liable, so an individual beneficiary can claim relief on their own income position. The position is the same for personal representatives as for the discretionary trust — where PRs are assessed on a gain (a bond that continues after death, say), the charge is at the basic rate with no top-slicing relief.

Who holds the bond changes the tax, not just the administration. Take the offshore case our engine regression-tests against: a £60,000 gain before any TAR over six years that attracts £8,846of top-slicing relief in an individual's hands attracts nonein a discretionary trust's. Same gain, taxed at the trust rate with no slicing. The five-step relief, for the cases where it is available, is on the top-slicing relief calculator; how the gain itself is computed is on the chargeable event gain calculator. For the mechanics of the relief, see how to calculate top-slicing relief.

Worked-example basis: No time-apportioned reduction is due for any gain or policy shown. TAR is not calculated or applied. Raw gains are shown before any TAR.

ITTOIA 2005 s.535 (relief for individuals) · ITTOIA 2005 ss.465–467 (persons liable) · IPTM3250 (trusts) · IPTM3240 (death cases — personal representatives)

Common questions

Can trustees claim top-slicing relief?: Generally no. Top-slicing relief is given to individuals (ITTOIA 2005 s.535). Where trustees of a discretionary or other non-bare trust are the person liable for a bond gain, the gain is taxed at the trust rate with no top-slicing relief.
Does a bare trust get top-slicing relief?: Yes. Under a bare trust the beneficiary is treated as the individual liable for the gain, so an individual beneficiary can claim top-slicing relief on their own income and allowances, just as if they held the bond directly.
Do personal representatives get top-slicing relief?: No. Where personal representatives are assessed on a chargeable event gain — for example a bond continuing after the policyholder’s death — the gain is charged at the basic rate with no top-slicing relief.
Why does it matter who holds the bond?: Because the relief follows the person liable for the gain. The same gain can attract substantial top-slicing relief for an individual and none at all for a discretionary trust — so the ownership structure changes the tax, not just the paperwork.

Sources & grounding

Rule basis: ITTOIA 2005 s.535 — top-slicing relief is given to an individual liable to income tax on a chargeable event gain. Persons liable: ITTOIA 2005 ss.465–467 (individual / personal representatives / UK trustees). IPTM3250 (the relevant person; trustees and personal representatives).
Primary sources:IPTM3250 ITTOIA 2005 s.535 ITTOIA 2005 ss.465–467 (individual / personal representatives / UK trustees). IPTM3250 (th
Discretionary/non-bare trust: where UK trustees are the person liable (s.467), the gain is taxed at the trust rate with no top-slicing relief, because the relief is by reference to an individual’s liability (IPTM3250).
Primary sources:IPTM3250
Bare trust: the beneficiary is treated as the individual liable and can claim. Personal representatives: gains assessed on PRs are charged at the basic rate with no top-slicing relief.
Illustrative contrast figure (£60,000 gain before any TAR → £8,846 relief for an individual, none for a discretionary trust): the engine’s IPTM-EX-03-OFFSHORE anchor, re-used to make the eligibility point concrete; the legal rule is qualitative. No time-apportioned reduction is due for the policy; TAR is not calculated or applied.

For planning and illustration purposes only. Verify all inputs against source documents. This explainer does not constitute financial or tax advice.

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