In the recent Budget, the Government committed itself to a review of the operation of trust taxation in the UK.

Since reforms were introduced in 2006 to counter what appear to have been little-used tax avoidance schemes, trusts have been used less often owing to their complexity and the perceived risk that their use may become subject to even more penal taxation. Offshore trusts, on the other hand, have been made subject to tighter rules in the Budget.

Additional measures include extending from April 2019 the taxation of capital gains on UK assets by non-residents to include all immoveable property and an extension in the time period to at least 12 years for HM Revenue and Customs to probe offshore financial arrangements without having to prove deliberate non-compliance with UK law. The current time limits are usually four, six or 20 years, depending on the behaviour that led to the non-compliance.


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