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New rules for non-UK resident trusts

Lynnette Bober tackles the complexities of the trust protection rules following changes to the anti-avoidance provisions for non-UK resident trusts introduced by Finance (No. 2) Act 2017 and Finance Act 2018.

Taxline image offshoreFundamental changes to the anti-avoidance provisions for non-UK resident trusts are being introduced by Finance (No. 2) Act 2017 and Finance Act 2018. This briefing covers some key issues.

My article in December 2017 TAXline gave an overview of the 2017 and 2018 changes affecting foreign domiciliaries and non-UK resident trusts. The Tax Faculty’s Finance Bill representations provide significant detail about the concerns we have with the technical aspects of the overseas trusts legislation. Further guidance for members will be published in the coming months.