Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) discuss the difficulties arising from the recent Finance Acts.
(Not so) protected settlements
Sweeping changes to the taxation of non-UK resident trusts with UK resident settlors were effected by F(No. 2)A 2017 and FA 2018. As part of these reforms the so-called ‘protected settlements’ regime was introduced in relation to offshore trusts created by foreign domiciliaries. This was intended to protect non-UK domiciled settlors from arising basis taxation in relation to non-UK income and gains of the trust.
Under this regime a non-UK domiciled settlor of a ‘protected settlement’ is not subject to tax on the arising basis in respect of ‘protected foreign source income’ (PFSI) of the trust even if the settlor has become deemed domiciled in the UK due to long-term residence. Instead the...
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:
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) discuss the difficulties arising from the recent Finance Acts.
(Not so) protected settlements
Sweeping changes to the taxation of non-UK resident trusts with UK resident settlors were effected by F(No. 2)A 2017 and FA 2018. As part of these reforms the so-called ‘protected settlements’ regime was introduced in relation to offshore trusts created by foreign domiciliaries. This was intended to protect non-UK domiciled settlors from arising basis taxation in relation to non-UK income and gains of the trust.
Under this regime a non-UK domiciled settlor of a ‘protected settlement’ is not subject to tax on the arising basis in respect of ‘protected foreign source income’ (PFSI) of the trust even if the settlor has become deemed domiciled in the UK due to long-term residence. Instead the...
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:
