A non-dom has set up an offshore trust of which one of the beneficiaries is resident in the UK. Questions include the gift of income from one beneficiary to another and the implications of dividends from a subsidiary company
A company is resident in both the UK and in Brazil and wonders whether loss relief will be available as group relief in the UK and by carry forward in Brazil. It seems to be that loss relief can be given in both countries but the operation of double taxation relief will mean that relief is only effectively given once