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Residence of trusts

Three professional bodies have joined forces to produce new guidance on the residence of trusts.

HMRC approved the guidance prepared by the CIOT the ICAEW Tax Faculty and the Society of Trust and Estate Practitioners which is available via

The note covers the practical application of ITA 2007 s 475(6) and TCGA 1992 s 69(2D).

Its publication follows concerns that the FA 2006 ‘trust modernisation changes’ to those rules ‘discourage settlors and trustees from using UK advisers’.

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