The onwards gift rules came into effect on 6 April 2018. Fiona Poole (Maurice Turnor Gardner) navigates the legislation.
Before a close examination of the onward gift rules (‘the rules’) it is important to review the taxation of beneficiaries of offshore trusts and recall the fundamental changes to the taxation of non-UK domiciled beneficiaries implemented in 2017 and 2018.
This article will then consider how the rules apply in relation to the CGT matching regime in TCGA 1992 s 87 and the transfer of assets abroad code (TOAB).
The settlements code also contains onward gift rules; however these are of limited application and so are not discussed here.
The drafting of the legislation in both s 87 and TOAB makes it is difficult to compare the provisions like-for-like. As an alternative to laboriously working through all the provisions in detail I will instead identify some...
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The onwards gift rules came into effect on 6 April 2018. Fiona Poole (Maurice Turnor Gardner) navigates the legislation.
Before a close examination of the onward gift rules (‘the rules’) it is important to review the taxation of beneficiaries of offshore trusts and recall the fundamental changes to the taxation of non-UK domiciled beneficiaries implemented in 2017 and 2018.
This article will then consider how the rules apply in relation to the CGT matching regime in TCGA 1992 s 87 and the transfer of assets abroad code (TOAB).
The settlements code also contains onward gift rules; however these are of limited application and so are not discussed here.
The drafting of the legislation in both s 87 and TOAB makes it is difficult to compare the provisions like-for-like. As an alternative to laboriously working through all the provisions in detail I will instead identify some...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
