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Residence & Domicile Review

In the second of a two-part article Janet Paterson and Richard Holme partners Creaseys LLP look at the draft legislation on residence and domicile and how it impacts on offshore trusts and companies
For practitioners involved with non-resident and non-domiciled clients it would be regarded as common practice to utilise offshore entities particularly trusts and companies in order to legitimately keep income and gains outside the UK tax net. The proposals discussed below would substantially change the existing scope for planning: the uses of offshore trusts and companies for tax planning purposes in the new regime would be very restricted. However there is a small but distinct window of opportunity between now and 5 April 2008 within which to take action to minimise the impact of some of these...

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