Finance Act 2008 made substantial changes to the taxation of individuals who are UK resident but not UK domiciled with effect from 6th April 2008. These changes have a significant impact on offshore structures (trusts and closely held companies of trusts) with UK resident but non-domiciled beneficiaries. In particular, capital gains realised in such a structure after 5th April 2008 will be attributed to a UK resident but non-domiciled individual who receives a capital payment from the trust after 5th April 2008. What is the rebasing election and what are the considerations for Trustees. Read on to find out more.
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