Offshore Trusts – Payments To UK Resident but Non Domiciled Beneficiaries: The Rebasing Election

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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