Many phrases could be used to describe the UK’s offshore anti-avoidance legislation. Extreme complexity will do. HMRC realise that the legislation is complex, and that significant tax can be at stake. As such, HMRC officers often take an interest in offshore issues. Domicile challenges continue and so do challenges to the motive defence. Nudge letters were sent out last year with respect to the deemed domicile provisions. Given the tax that the F(No.2)A 2017 trust protections could save, enquiries to see if an offshore trust settled by a LTR has been tainted can be expected. The Wealthy Unit is looking at the onward gift area (one of the additional anti-avoidance provisions brought in by FA 2018).
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Many phrases could be used to describe the UK’s offshore anti-avoidance legislation. Extreme complexity will do. HMRC realise that the legislation is complex, and that significant tax can be at stake. As such, HMRC officers often take an interest in offshore issues. Domicile challenges continue and so do challenges to the motive defence. Nudge letters were sent out last year with respect to the deemed domicile provisions. Given the tax that the F(No.2)A 2017 trust protections could save, enquiries to see if an offshore trust settled by a LTR has been tainted can be expected. The Wealthy Unit is looking at the onward gift area (one of the additional anti-avoidance provisions brought in by FA 2018).
If you are not a subscriber, subscribe now to read this content.
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