The CIOT notes that the current offshore anti-avoidance provisions are outdated and confusing suggesting that the various legislative provisions should instead be unified into one anti-avoidance code applying for income and capital gains from international trusts and companies with a single motive defence at the corporate level and a clearance procedure for certainty.
The response includes suggested draft clauses and schedules to illustrate the proposed structure.
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The CIOT notes that the current offshore anti-avoidance provisions are outdated and confusing suggesting that the various legislative provisions should instead be unified into one anti-avoidance code applying for income and capital gains from international trusts and companies with a single motive defence at the corporate level and a clearance procedure for certainty.
The response includes suggested draft clauses and schedules to illustrate the proposed structure.
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: