Double taxation relief

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Practice notes
Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:•non-distributor offshore funds, or...
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9th Nov
Practice notes
The issue of sham is most likely to be raised by the settlor's creditors or former spouse if the settlor is involved in matrimonial proceedings, who...
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9th Nov
Practice notes
A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or persons (the trustees) to hold...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
When trustees are engaged in trust litigation, issues often arise as to how their litigation costs are to be funded. A Beddoe application is the best...
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Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside Chambers 12th Jan
Practice notes
This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...
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Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 12th Jan
Practice notes
This Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman Islands, see Practice Note: Private...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
Trust litigation has been classified as being of three types:•a dispute as to the trusts on which trustees hold the subject matter of the settlement•a...
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9th Nov
Practice notes
Where a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married under that date but is required...
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9th Nov
Practice notes
Duration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules against remoteness of vesting and against the...
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9th Nov
Practice notes
Duty to distribute to the correct beneficiariesOn the termination of the trust, the trustees are under a duty to distribute the trust assets to the...
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9th Nov
Precedents
This Deed of Appointment is made on [date] by [trustee] of [address] and [trustee] of [address] (the Trustees).Background(A)This Deed is supplemental...
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9th Nov
Practice notes
When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets...
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9th Nov
Precedents
This partial deed of revocation is made on [date] by [donor] of [address].1I granted a Lasting Power of Attorney for [Financial Decisions/Health and...
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9th Nov
Practice notes
Liferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both, in the trust property...
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Produced in partnership with Peter Murrin of Turcan Connell 12th Jan
Practice notes
An offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK inheritance tax (IHT) is not dependent on the...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 12th Jan
Practice notes
Express creation of trustsA trust is constituted expressly where the owner of property (the truster) transfers property to trustees to hold for...
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Produced in partnership with Yvonne Evans, Law Lecturer, Solicitor (non-practising), TEP, University of Dundee 12th Jan

Most recent Double taxation relief content

Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 15th Apr
Practice notes
What are the anti-avoidance concerns in a double tax treaty context?As discussed in Practice Note: What are double tax treaties?, one of the aims of...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
Double tax treaties (DTTs) allocate taxing rights between jurisdictions, with the primary aim of ensuring that taxpayers do not suffer tax on the same...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
This Practice Note explains some of the key definitions and concepts a tax lawyer will come across when dealing with a double tax treaty or double tax...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
Double tax treaties or conventions (DTTs) have a dual nature. They are:•conventions between states (the contracting states), governed by international...
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Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
Read More >
Produced in partnership with David Klass of Hunton Andrews Kurth 9th Apr
Practice notes
Many investors in UK property are based outside the UK. The UK real estate sector is attractive to a range of investors, from high net worth...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
Unilateral relief may be available as a credit against UK inheritance tax (IHT) where a tax of a character similar to IHT has been imposed on property...
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Produced in partnership with Andrew Godfrey and Yousafa Hazara of Russell-Cooke Solicitors LLP 9th Apr
Practice notes
International tax law is mostly concerned with the taxing rights of states. As with all forms of international law, the need to deal with such issues...
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9th Apr
Practice notes
AAdministrationThe process starting on the date of the deceased's death and ending on the date the deceased's affairs are finalised by his personal...
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9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with David Klass of Hunton Andrews Kurth 1st Mar
Q&As
What are the UK’s automatic exchange of information obligations with Guernsey?There are three relevant sources of law on this topic:•Double Taxation...
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3rd Feb
Q&As
The concepts of residence and domicile are used to establish the extent of an individual's liability to UK taxation. For more detail, see Practice...
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22nd Jan

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