Edward Hayes (Burges Salmon) explains what settlors and trustees should be doing now in light of the Spring Budget announcements.
Background
This article won’t repeat all of the changes announced to the non-dom regime last week as most readers will now be familiar with the core proposals. However in the context of non-UK resident trusts it is worth reiterating that:
for income tax and capital gains tax: protected trusts will lose that status from 6 April 2025 (no matter when they were settled); and
for inheritance tax:
excluded property trusts established by 5 April 2025 will retain that status indefinitely (so broadly they should continue to be exempt from inheritance tax to the extent they hold only non-UK situated assets); but
the treatment of a trust established on or after 6 April 2025 is currently unclear (see below).
The IHT treatment of post-5 April 2025 trusts
The...
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Edward Hayes (Burges Salmon) explains what settlors and trustees should be doing now in light of the Spring Budget announcements.
Background
This article won’t repeat all of the changes announced to the non-dom regime last week as most readers will now be familiar with the core proposals. However in the context of non-UK resident trusts it is worth reiterating that:
for income tax and capital gains tax: protected trusts will lose that status from 6 April 2025 (no matter when they were settled); and
for inheritance tax:
excluded property trusts established by 5 April 2025 will retain that status indefinitely (so broadly they should continue to be exempt from inheritance tax to the extent they hold only non-UK situated assets); but
the treatment of a trust established on or after 6 April 2025 is currently unclear (see below).
The IHT treatment of post-5 April 2025 trusts
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:
