Administrative doctrine on the tax implications of a trust

1. The position of the DGT
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As is known, a trust is a device regulated in common law countries, by means of which one or more persons (settlors) provide for, inter vivos or mortis causa, the establishment of a separate fund (trust), assigning it to a fiduciary (trustee) who is required to manage and administer the same in accordance with the instructions received and for the benefit of another person or persons (the beneficiaries)…