Loans from offshore trusts
In Cooper v Billingham [2001] STC 1177 it was held that, where non-resident trustees made interest-free loans repayable on demand to a beneficiary, this was the provision of a benefit from the trust within section 97(4), Taxation of Chargeable Gains Act 1992. Accordingly the value of the benefit was a capital payment for the purposes of the capital gains provisions relating to offshore trusts.
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