Individuals who become deemed domiciled from 6 April 2017 and who set up trusts and underlying companies on or after this date will see the structures generally treated as tax transparent in the UK. This could include UK charges on the individual on income and gains from assets in an offshore structure without there necessarily being any cash distributions to the individual. While Trusts can still offer asset protection and other benefits they are unlikely to provide tax advantages in such situations. However there is protection provided for trusts established before individuals become deemed domiciled on 6 April 2017 ("protected trusts").
Existing trusts and underlying companies should be reviewed before 6 April 2017 to ensure they achieve optimal protection for the individuals when the changes are introduced. The changes will impact trusts where the settlor, spouse, civil partner or children can benefit. If the settlor died before 6 April 2017 and was UK resident but non-domiciled and close members cannot benefit from the trust, the changes will have less effect.
IQE has a history of providing fiduciary services including the provision of a corporate trustee, administration, bookkeeping and maintaining accounting records for Isle of Man trusts. With many years' experience dealing with a range of trusts for international clients IQE offers a reliable and responsive service built on integrity and expertise. IQE works closely with professional advisers to ensure that the structures are correctly implemented.
To arrange a meeting or a telephone call, contact Anne Couper Woods on +44 (0) 1624 689596 / email firstname.lastname@example.org or David Karran on +44 (0) 1624 689581 / email email@example.com.
We have the expertise to assist with multi-jurisdictional fiduciary services for international structures
On a recent transaction we worked closely with IQE to set up and run a corporate structure to facilitate a new residential development in London. We found the IQE team responsive and proactive. It was clear that their property experience added value and understanding of the clients’ requirements on the project. Christine Jackson, Partner, Real Estate Group, Lawrence Graham LLP