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The quest for the grail
KEY POINTS
- New rules were introduced by F(No 2)A 2017 but with retrospective effect from 6 April 2017.
- Settlors are prevented from obtaining preferable tax treatment.
- There is no unified concept across the taxes of when a trust qualifies as settlor interested.
- The consequences of a trust being settlor interested differ depending on the tax concerned.
- The gift with reservation of benefit rules can result in double taxation.
- Trusts may have protected status but could this lead to a false sense of security?
Tax practitioners across the land have been left pondering the operation of the rules on the protection of overseas trusts. The rules are a knight in shining armour for some deemed domiciled settlors. Their preparation for battle was slow: the draft legislation was...
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