Offshore anti-avoidance regimes

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Practice notes
IHT—quick succession reliefQuick succession relief (QSR), which is not to be confused with taper relief, applies to a transfer of value which attracts...
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Produced in partnership with Katya Vagner of PwC 19th May
Practice notes
Liferent trusts—ScotlandLiferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both,...
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Produced in partnership with Peter Murrin of Turcan Connell 19th May
Practice notes
What is an offshore trust?A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or...
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Produced in partnership with Mourant Ozannes and Carey Olsen 19th May
Practice notes
CGT—reliefsFORTHCOMING CHANGE: On 14 July 2020, the Office of Tax Simplification (OTS) published its online survey and a call for evidence to seek...
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19th May
Q&As
When can a mistake in an executed deed be rectified by a manuscript amendment rather than by a deed of rectification?This Q&A explains when it is...
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Produced in partnership with Emma Holland of Stewarts Law 19th May
Practice notes
Trustees—removal of trusteesA trustee may be removed against their will in any of the following ways:•under an express power in the trust...
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19th May
Q&As
At what stage and to whom can a Deed of Appropriation take place when selling a second property in an estate?We assume you refer to the situation when...
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19th May
Practice notes
Creation of trusts—blind trustsWhat is a blind trust?A blind trust is a trust that is aimed at preventing conflicts of interest arising. Usually, the...
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Produced in partnership with Michael O’Sullivan of 5 Stone Buildings 19th May
Q&As
Can a life tenant in a Will bring a life interest to an end by choosing to end it themselves or does it only expire on death?Life tenantsA life...
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Produced in partnership with Lynne Counsell of 9 Stone Buildings 19th May
Practice notes
Costs and expenses in the Court of ProtectionThere are court fees and disbursements which will be payable by all applicants on making a new...
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19th May
Practice notes
Offshore trusts—offshore income gains (OIGs)Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are...
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19th May
Practice notes
Acceptance in Lieu scheme and other heritage property reliefsSTOP PRESS: HMRC has updated its guidance on calculating the special price in Acceptance...
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19th May
Practice notes
Trustees—power of advancementWhere a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married...
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19th May
Practice notes
Cayman Islands STAR trusts—common usesThis Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman...
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Produced in partnership with Mourant Ozannes and Carey Olsen 19th May
Practice notes
Discretionary trusts—ScotlandWhat is a discretionary trust?A discretionary trust or discretionary settlement is an arrangement created when an...
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Produced in partnership with Peter Murrin of Turcan Connell 19th May
Practice notes
Beneficial ownership registers—private clients and trustsCORONAVIRUS (COVID-19): Certain aspects of the PSC regime are affected by temporary measures...
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19th May

Most recent Offshore anti-avoidance regimes content

Practice notes
When do the UK transfer pricing rules apply?Scope of UK transfer pricing rulesThe UK transfer pricing rules apply for UK corporation and income tax...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 3rd Aug
Q&As
A non-resident trustee disposes of a UK residential property in the tax year 2017/18. The trust was settled by a UK domiciled settlor in 2002. How...
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1st Aug
Q&As
Coronavirus (COVID-19)—what is the potential impact on transfer pricing?There are a range of issues that could arise for transfer pricing purposes,...
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Produced in partnership with Kapisha Vyas of Simmons & Simmons and Tomoko Ikawa of Simmons & Simmons 1st Aug
Q&As
Are there any disguised remuneration consequences of leaving shares to an employee under a Will?This Q&A considers whether the provisions set out in...
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Produced in partnership with Christopher Snell of New Square Chambers 31st Jul
Practice notes
Tax consequences for close companiesSummary of tax considerationsThe concept of a close company is intended to capture those companies that are...
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31st Jul
Practice notes
Disguised remuneration and the self-employedCoronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary...
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Produced in partnership with Karen Cooper of Cooper Cavendish 31st Jul
Practice notes
Offshore trusts—capital payments to UK resident non-domiciliaries and applicable reliefsAs discussed in the UK resident non-domiciliaries—tax planning...
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31st Jul
Practice notes
Offshore trusts—attribution of income to settlorsThis Practice Note considers the provisions of part 5, sections 619–648 of the Income Tax (Trading...
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31st Jul
Practice notes
Transfer of assets abroad—transferors receiving capital sumsThis Practice Note considers the charging provision under section 727 of the Income Tax...
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31st Jul
Practice notes
Offshore trusts—benefits and capital payments to UK resident beneficiariesIncome, capital gains and offshore income gains (OIGs) of an offshore trust...
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31st Jul
Practice notes
Transfer of assets abroad—introductionTransfer of Assets Abroad CodeThe anti-avoidance provisions relating to a transfer of assets abroad are...
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31st Jul
Practice notes
Transfer of Assets Abroad—EU DefenceTransfer of Assets Abroad CodePart 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains a key UK...
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Produced in partnership with James Quarmby of Stephenson Harwood 31st Jul
Practice notes
Offshore trusts—the trustee borrowing rules—Sch 4B and Sch 4C TCGA 1992The trustee borrowing rules were introduced in 2000 to counter a specific...
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Produced in partnership with Dhana Sabanathan of Winckworth Sherwood 31st Jul
Practice notes
Shadow director issues and benefits in kindThis Practice Note considers shadow directors of offshore companies and the extent to which such directors...
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Produced in partnership with Stephen Parnham 31st Jul
Practice notes
Taxation of offshore trusts—non-domiciled and deemed domiciled settlorsSignificance of settlor’s domicile for offshore trustsThe extent of a trust’s...
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31st Jul
Practice notes
Transfer of assets abroad—the benefits chargeThis Practice Note considers the charging provisions on individuals under section 731 of the Income Tax...
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31st Jul
Practice notes
Glossary of UK trust and taxation law terms for international clientsAAdministrationThe process starting on the date of the deceased's death and...
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31st Jul
Practice notes
Offshore trusts—transfers between settlements—offshore income gains (OIGs) and s 1(3) amountsCapital payments are generally taxed by matching them...
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31st Jul

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