Hi all, does anyone know anything about distributing income (profit made) or Capital Gains accrued in a Discretionary Trust, to a beneficiary that is a Trustee of another Discretionary Trust? For example, if one company is acting as Trustee to two separate Discretionary Trusts, can profit from one easily be transferred to the other without any tax implications or CGT being activated? The reason I ask is someone mentioned that a loss in one Trust could be filled from a profit made in the other, effectively wiping out any tax obligation on the profit. Does this apply to any trusts or only certain specific ones? I found the below which may be related. If so it seems best to only set this sort of thing up from the very beginning when all details of the two Trusts are identical, is that correct? TR 2005/D15 (Finalised) - Income tax: capital gains: meaning of the words 'the beneficiaries and terms of both trusts are the same' in paragraphs 104-55(5)(b) and 104-60(5)(b) of the Income Tax Assessment Act 1997 (As at 28 September 2005) If possible, please provide any links to source material, it would be most appreciated. Thanks very much.