Why Dutch Sandwiches are off the menu in Overseas Territories and Crown Dependencies

Contrary to popular belief, international tax planning is not so much about avoiding tax. Usually advisers help their clients avoid being taxed more than once on the same profits. Use of Dutch Sandwiches or Subsidiary Companies It is not uncommon for a subsidiary company to pay local tax on its trading revenues, then declare a…

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Protected Trusts – what action should our clients take?

HAVE PROTECTED TRUSTS TURNED INTO FALSE PROMISES? Those worrying about what else has been neglected, whilst the UK government’s attention is wholly fixed on Brexit and infighting, will take no comfort from HM Revenue’s recent statement that offshore income gains are not within the new Protected Trusts regime. Background The introduction of the Deemed Domicile rules for income and capital gains tax from April 2017 ended the unlimited access…

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Cleansing and rebasing opportunities for non-doms – time to act

A window of opportunity for cleansing and rebasing Those heading for deemed domiciled status have opportunities to protect their assets now through protected trusts, cleansing and rebasing assets. What is a ‘nondom’? A nondom is someone with a foreign (non-UK) domicile. Domicile is a curious concept in English law. It is not the same as tax…

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UK Trusts Registration Service – non-resident trusts need to comply

HM Revenue & Customs (“HMRC”) has announced that the online central register for trusts, the “Trusts Registration Service”, will be launched very shortly. The register has been brought in to assist the UK government comply with the EU’s 5th Money Laundering Directive which came into force on 26 June 2017. Trustees anywhere in the world…

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Priya Dutta comments on Trust Ownership Register

Trust Ownership Register: The U.K. tax authority has missed the deadline to launch its online register for the beneficial ownership of trusts as the government grapples with the legislative fallout of this month’s snap general election. HMRC were expected to launch their online beneficial ownership register for trusts on 26 June which would give it…

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HMRC plans to demand details of Offshore Trusts and companies from their Advisers

The Law Society has learned that HM Revenue and Customs (‘HMRC’) intends to write to firms that advise clients on the establishment of offshore trusts and companies, seeking information about beneficial ownership. The letter will precede a formal Notice under Schedule 23 Finance Act 2011, which will compel the recipient to provide information.    We…

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