The onward gift rules can have the effect of taxing a distribution from an offshore trust if that distribution has been made to a non-UK resident person (who would not be taxable) and that non-UK recipient passes on the distribution to a UK resident (who would be taxable had he received it directly from the trust). The legislation has been drafted in such a way that it can be incredibly complicated to unpick but once deciphered can deliver some interesting results.
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The onward gift rules can have the effect of taxing a distribution from an offshore trust if that distribution has been made to a non-UK resident person (who would not be taxable) and that non-UK recipient passes on the distribution to a UK resident (who would be taxable had he received it directly from the trust). The legislation has been drafted in such a way that it can be incredibly complicated to unpick but once deciphered can deliver some interesting results.
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:
