In L Tang v HMRC [2019] UKFTT 81 (6 February 2019) the FTT accepted the existence of a bare trust despite the absence of a trust document.
Mrs Tang a midwife in the NHS held over $900 000 in her name (or jointly with others) initially in London and then in banks in the Far East. She contended that she held the funds as bare trustee for her parents-in-law who were resident in Hong Kong so that she had no personal liability to tax in relation to these funds. She also argued that she had no obligation to complete a tax return as she was a basic rate taxpayer and all the tax due was deducted under PAYE in relation to her salary and by a building society in relation to a small amount of interest she received. HMRC considered however that...
