Avoidance, like beauty, is in the eye of the beholder. In 1988, government ministers said that they will mitigate the effects of the decision of EC v UK of 1988, by introducing the option to tax for commercial property. Bizarrely, by 1997 this retrospectively became “mitigate but only for taxable businesses”. Bizarre but true, but

Briefing note Headlines Anti-gains washing provisions withdrawn but HMRC are thinking of other solutions to the problem which they perceive to exist. Deemed UK domicile applies from 6th April 2017. Transitional rules for mixed funds and grandfathering of existing excluded property trusts. AUGUST 2017 Update on the UK’s non-domiciled status Who should read this? Anyone

Briefing Note Headlines You will become deemed UK domiciled (DUD) on 6th April 2017 either if you were born here or you are already in your 15th tax year of UK residence in the last 20. Rules apply from 6th April of RND’s 16th tax year. CGT rebasing for RNDs only. Trustees have to consider

Briefing note Headlines Trustees of related party trusts.   To the extent your trust has assets attributable to UK residential property you are now within the ten year charge regime. The charge is basically 6% of net asset value every ten years. Related party debts included as is collateral supporting third party debt. Being a

Briefing Note Headlines A non-UK trust of which one of its trustees is UK resident will become UK resident when settlor becomes deemed UK domiciled. Rules apply from 6th April of RND’s 16th tax year. CGT rebasing for RNDs only. Trustees have to consider planning. Some grandfathering for pre 6th April 2017 non-UK trusts. Washing

Briefing note Headlines No exemption for buy to let Non-close companies excluded Related party debts included as is collateral supporting third party debt Likelihood of HMRC collecting 40% IHT is remote amongst the well advised Dry trusts unaffected (ten year charge applies) Life insurance is still a viable option Other – reliefs remain available to

At the end of the day, governments need to raise sustainable amounts of revenue, to fund public services, the welfare state, and other common goods. More than ever, however, they have to compete for business and investment from companies and investors who have more options than ever before. Tax too high or tax capriciously and