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Offshore trusts and onward gifts

Speed read
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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