When reading your last post, Brian, I had understood it to fall within the first type of accumulation units referred to in my posting of 8 June.
I have not previously come across a unit trust where a distribution is declared and rolled up within the existing units. In any such situation, even if the declared distribution were not to be deemed the income of a life tenant, I suspect it could still be income of the trustees for the purpose of assessing the trustees’ liability to tax under s.479 Income Tax Act 2007.
Paul Saunders