David, thanks for your reply. I probably didn’t make it clear but I am not looking at any apportionment to individual trustees. I am happy that the trustees are a single body and that one doesn’t look through to the various persons comprising the trustees.
Patrick, treating the trustees as neither an individual or company makes sense but doesn’t that give an odd result in step 2(b) of para 12? If there is a company acting as a trustee then that company can be an indivdual for the purposes of step 2(b) by virtue of sub para 3, whereas an individual acting as a trustee is not an individual for the purposes of step 2(b).
Applying the treatment to para 24, I assume that if the trustee is a company then it will be a body corporate. In which case replacing a corporate trustee with individual trustees would potentially be a route out of any para 24 problem?