Andrew Goldstone and Natalie Quail (Mishcon de Reya) review the latest tax developments that matter affecting private clients.
Draft Finance Bill clauses on the income tax treatment of offshore trust structures
On 26 January 2017 the government published further draft legislation and explanatory notes on the reforms to the taxation of non-domiciled individuals for inclusion in the Finance Bill 2017. The draft legislation notably includes the much anticipated draft clauses on the income tax treatment of offshore trust structures.
Under current rules the key provision for transferors such as settlors of offshore trusts are in ITA 2007 s 720 which attributes income arising within an offshore structure to the ‘transferor’. Only UK resident transferors are caught by these rules. Section 720 is similar in effect to s 624 of the settlements legislation and the two provisions often overlap. However there are differences. Section...
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Andrew Goldstone and Natalie Quail (Mishcon de Reya) review the latest tax developments that matter affecting private clients.
Draft Finance Bill clauses on the income tax treatment of offshore trust structures
On 26 January 2017 the government published further draft legislation and explanatory notes on the reforms to the taxation of non-domiciled individuals for inclusion in the Finance Bill 2017. The draft legislation notably includes the much anticipated draft clauses on the income tax treatment of offshore trust structures.
Under current rules the key provision for transferors such as settlors of offshore trusts are in ITA 2007 s 720 which attributes income arising within an offshore structure to the ‘transferor’. Only UK resident transferors are caught by these rules. Section 720 is similar in effect to s 624 of the settlements legislation and the two provisions often overlap. However there are differences. Section...
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:
