Offshore anti-avoidance regimes

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Practice notes
The term 'relevant property' defines a category of trust property which is subject to a special regime for inheritance tax (IHT). As described in...
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Produced in partnership with Paul Davies of Clarke Willmott 12th Jan
Practice notes
On the face of it, there would appear to be no specific impediment, if there is no reason to suppose that a person is without capacity, in them...
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9th Nov
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 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
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 Offshore anti-avoidance regimes content

Practice notes
This Practice Note is about the rules that can impose a charge to tax on UK persons holding interests in a non-UK resident company if that company...
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9th Apr
Practice notes
IntroductionHMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to income tax and National...
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Produced in partnership with Karen Cooper of Cooper Cavendish 9th Apr
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support the self-employed. For more...
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Produced in partnership with Karen Cooper of Cooper Cavendish 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 Simon Gough and Caroline Brown of Bird & Bird LLP 9th Apr
Practice notes
Summary of tax considerationsThe concept of a close company is intended to capture those companies that are closely controlled (ie by the owners and...
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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...
Read More >
Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 9th Apr
Practice notes
Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty territory (ie not resident in a territory with which the UK...
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9th Apr
Practice notes
Transfer of Assets Abroad CodeThe anti-avoidance provisions relating to a transfer of assets abroad are contained in Chapter 2, Part 13 of the Income...
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9th Apr
Practice notes
This Practice Note is based on material provided by Tolley and Milestone International Tax Partners LLP, but is now maintained by PSL Private...
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9th Apr
Practice notes
Capital payments are generally taxed by matching them against available relevant income (ARI), offshore income gains (OIGs) and capital gains in that...
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9th Apr
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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9th Apr
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
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9th Apr
Practice notes
This Practice Note considers the charging provisions on individuals under section 731 of the Income Tax Act 2007 (ITA 2007), also known as ‘the...
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9th Apr
Practice notes
Capital payments made by an offshore trust to UK resident-domiciled beneficiaries are governed by a series of 'tax hierarchy' rules.The order in which...
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9th Apr
Practice notes
FORTHCOMING CHANGE: As announced at Budget 2018, draft legislation to be included in Finance Bill 2019–20 was published on 11 July 2019 and includes a...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 9th Apr
Practice notes
The Offshore bonds and other foreign policies Practice Note discusses what is meant by an offshore bond and a foreign policy and it explains the tax...
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Produced in partnership with Simon Gorbutt 9th Apr
Practice notes
This Practice Note considers the provisions of part 5, sections 619–648 of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005) (Ch 5)...
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9th Apr
Practice notes
When is Sch 4C in point?A Sch 4C pool, ie a pool of gains to which Schedule 4C to the Taxation of Chargeable Gains Act 1992 (TCGA 1992) applies, is...
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9th Apr
Practice notes
Part 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains key UK anti-avoidance provisions known as the transfer of assets abroad code (TAA...
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Produced in partnership with James Quarmby of Stephenson Harwood 9th Apr
Practice notes
Major changes to the taxation of offshore trusts were introduced in 2017 and 2018. These changes are summarised in Practice Note: Changes to the...
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9th Apr

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