This Practice Note explains what is meant by offshore bonds and foreign policies and the tax charges that are likely to arise under the chargeable event regime set out in Chapter 9 of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005). What is a bond? The word 'bond' has a number of meanings. In a financial context, the term can refer to government bonds (also known as 'gilts'), and corporate bonds, under the terms of which the investor lends money to the government or to a company, often in exchange for a guaranteed return after a fixed period. For more information on this form of bond, see Investments and advice—Gilts. National Savings Bonds are an example of a type of loan to the government. For more information on National Savings Bonds, see Investments and advice—National Savings. The term ‘bond’ can also refer to a type of life insurance policy, of which an ‘offshore bond’ is an example. This Practice Note discusses the taxation of offshore bonds and

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 charges likely to arise. This Practice Note covers several more specialised areas: cluster policies (also referred to as segmented policies), personal portfolio bonds (PPBs), the treatment of some older policies and the interaction between the foreign policy rules and the remittance basis and temporary non-residence rules. Cluster (or segmented) policies Rather than issuing a single insurance policy, some insurers will issue a series of policies to each policyholder, often referred to as a 'cluster' or 'umbrella' of smaller ‘segments’. Each policy or segment is an insurance contract in its own right. At the outset all segments are identical. They may also have the same number, apart from a sub-designation. For example, the cluster may be numbered XP234567/1-100, where numbers 1-100 identify the individual segments. The insurer might only issue a single policy document for all segments. UK insurers can usually issue cluster policies, and offshore bonds are

These are tables of cases , categorised by jurisdiction discussing matters including offshore trusts, offshore tax evasion, double taxation treaties, conflicts of laws in relation to Private Client and tax rules on residence status. Guernsey Case name and citation Summary Further coverage (where available) Appeal status (where applicable) Pilatus (PTC) Limited v RBC Trustees Limited [2025] GCA091 The Guernsey Court of Appeal allowed an appeal against a former trustee, holding that a trustee’s duty is not limited to preserving a chose in action (here, a trust-held option to reacquire SOIL, exercisable until February 2017) but extends to taking prudent steps to safeguard its value, including preventing foreseeable harm to connected non-trust assets where the trustee has practical means to do so. The trustee resigned in October 2015 as part of coordinated resignations without securing replacement directors for PIL and PFHL, allegedly enabling the other shareholder to gain control and diminish the option’s value when it was exercised in 2017. Treating the option as trust property under the Trusts (Guernsey) Law 2007 and relying on Elder’s Trustees v Higgins

Since 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These facilities provided a limited opportunity for individuals to come forward voluntarily to clean up their tax affairs with lower penalties than would be suffered by those who did not come forward and were later caught by HMRC. This Practice Note provides a brief introduction to the: • Offshore Disclosure Facility (ODF), which closed in 2007 • New Disclosure Opportunity (NDO), which closed in 2010 • Liechtenstein Disclosure Facility (LDF), which closed in 2015 • UK-Swiss Tax Co-operation Agreement (Agreement) which closed on 31 December 2016 • Jersey, Guernsey and Isle of Man Disclosure Facilities (Crown Dependency Disclosure Facilities), which closed in 2015 • Worldwide Disclosure Facility (WDF) Offshore Disclosure Facility The ODF was launched by HMRC in April 2007 to coincide with HMRC obtaining information about overseas account holders from five major clearing banks using its powers under section 20(8A) of the Taxes Management Act 1970 (since replaced by Schedule 36, paragraph 5 to the Finance Act 2008). The

This Practice Note explains the income tax provisions that apply to offshore employment intermediaries, including a summary of the position before and after the changes introduced by the Finance Act 2014 (FA 2014), and key practical considerations to be aware of. The offshore employment intermediaries legislation broadly applies when an offshore employment intermediary entity is used to facilitate the provision of the services of UK workers. The legislation is largely aimed at ensuring that employment taxes, in particular National Insurance contributions (NICs), are paid where offshore employers employ UK workers who are ultimately working for UK-based companies. For details about the position for onshore employment intermediaries, see Practice Notes: Onshore employment intermediaries—income tax provisions and Onshore employment intermediaries—key practical considerations. Note that when considering employment intermediaries structures, certain other rules should also be considered, namely: • the general IR35 legislation (for further details, see Practice Note: IR35—the small client off-payroll regime) • the IR35 regime applicable to off-payroll working (for further details, see Practice Note: IR35—the large and

For UK tax purposes, a fund'>mutual fund within the meaning of section 355(1) of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010).

A type of capital gains taxable as income which arises on the disposal of: • an interest in a non-qualifying fund, or • an interest in a distributing fund that operates equalisation arrangements

A type of capital gain taxable as income which arises on the disposal of an interest in a reporting-fund'>non-reporting fund.

Introduction This Practice Note covers environmental compliance related to the operation of offshore installations/infrastructure in England and Wales. This is a complex area and there are many areas of regulation, ranging from the requirement for environmental assessment, the need for environmental permits, licences and consents, marine conservation requirements, and measures relating to the avoidance of pollution, marine noise, chemicals and energy efficiency and emissions. Requirements will vary depending on the type of project. Additional regimes will also need to be complied with which are beyond the scope of this Practice Note, for example marine planning requirements will need to be followed and necessary building controls and design and safety standards will need to be complied with, as well as applicable health and safety legislation and decommissioning requirements. In addition, permission may be needed from the Crown Estate or the relevant landowner to access the seabed or foreshore and admiralty consent may be required under local legislation. For more information, see: • Marine planning—overview • Building regulations for construction lawyers—overview • Design in construction projects—overview • Health and safety in the

Law360: Two UK residents aren't liable for taxes tied to certain payments from an affiliated offshore company to a third-party foreign corporation, the Upper Tribunal (UT) ruled on 25 March 2024, finding the underlying transactions didn't amount to services that would trigger taxation.

This Practice Note provides an outline of the enhanced or specific sanctions that apply where a person is involved in non-compliance, avoidance or evasion with an offshore angle, including the following measures: • the offshore penalties for non-compliance regime • requirement to correct past offshore tax non-compliance • 12 year time limit for offshore non-compliance • publishing details of deliberate tax defaulters • civil sanctions for enablers of offshore evasion • penalty for UK facilitators of offshore promoters of tax avoidance schemes • criminal offences for offshore tax evaders • corporate offence of failure to prevent the criminal facilitation of tax evasion For details of the current general penalties regime, see the Tax penalties, interest and time limits—overview subtopic. See also: Timeline of penalties, sanctions and criminal offences in relation to offshore tax matters. The offshore penalties for non-compliance regime Where tax non-compliance involves an offshore matter, a tougher regime imposing higher penalties can apply. In broad outline, the offshore tax non-compliance regime increases the penalties for: • errors on a return • failure to notify, and

ARCHIVED: Section 20 of the Finance Act 2025 (FA 2025) abolished the offshore receipts in respect of intangible property (ORIP) rules for income arising on or after 31 December 2024. Consequently, the ORIP rules are only relevant to receipts arising on or after 6 April 2019 until and including 30 December 2024. ORIP was abolished because the undertaxed profits rule (UTPR), which took effect in the UK on 31 December 2024, is expected to 'more comprehensively discourage the multinational tax-planning arrangements that ORIP sought to counter'. HMRC’s guidance at INTM620710 confirmed that for the 2024–25 tax year, entities within the scope of ORIP only need to report ‘UK-derived amounts’ arising prior to 31 December 2024. For more information on the UTPR, see: Multinational top-up tax and domestic top–up tax—overview. From 6 April 2019 until and including 30 December 2024, a person that was neither UK tax resident nor resident in a full treaty territory (ie not resident in a territory with which