Deemed income of settlor of offshore trusts outside the protected settlements regime
In V Louwman v HMRC [2025] UKFTT 295 (TC) (7 March) the FTT decided that offshore income gains and accrued income profits of offshore settlements settled by the taxpayer before she became deemed UK domiciled were not ‘protected foreign-source income’ under the protected settlements regime. Accordingly the taxpayer was liable to income tax on an arising basis under the transfers of assets abroad rules.
This case concerned the taxpayer’s income tax liabilities for 2018/19 2019/20 and 2020/21. The taxpayer was a resident and domiciled in the UK for those years having become deemed domiciled on 6 April 2018. She had previously settled shares into four offshore trusts. The shares were in companies that owned investments with offshore income gains (OIG) and accrued income profits (AIP) in the relevant tax years. Broadly speaking...
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:
Deemed income of settlor of offshore trusts outside the protected settlements regime
In V Louwman v HMRC [2025] UKFTT 295 (TC) (7 March) the FTT decided that offshore income gains and accrued income profits of offshore settlements settled by the taxpayer before she became deemed UK domiciled were not ‘protected foreign-source income’ under the protected settlements regime. Accordingly the taxpayer was liable to income tax on an arising basis under the transfers of assets abroad rules.
This case concerned the taxpayer’s income tax liabilities for 2018/19 2019/20 and 2020/21. The taxpayer was a resident and domiciled in the UK for those years having become deemed domiciled on 6 April 2018. She had previously settled shares into four offshore trusts. The shares were in companies that owned investments with offshore income gains (OIG) and accrued income profits (AIP) in the relevant tax years. Broadly speaking...
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:
