This is true for discretionary beneficiaries. It is important to note that the Implementation Handbook makes a distinction between beneficiaries entitled to ‘mandatory’ distributions and those who are discretionary without any enforceable rights to receive trust property. As such, the RFI must identify whether their beneficiaries are discretionary or mandatory and report according. 

 A discretionary beneficiary will be reported in the year when the distribution is made, however, a mandatory beneficiary is reported regardless of whether or not the distribution is made. The handbook continues to outline that where the FI does not otherwise calculate the account value, the financial activity that should be reported in the case of a mandatory beneficiary is the total value of all trust property and the total gross amount paid or credited to the beneficiary in the reporting period.