UK Domicile Trust Protections Under Review by HMRC

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An unpublished examination has presumed that the trust protection regulations currently in place in the UK certainly shield settlors’ income gains from overseas trusts that were established before they became legally domiciled in the UK.

The Finance (No 2) Act 2017 & the Finance Act 2018 both have recognizable loopholes in the form of clauses that seemed to suggest that overseas income is excluded in the protections. The examination has now been forwarded to the HMRC, which is currently considering its suggestions for the 2017-2018 esteemed domiciled inhabitants’ assessment forms.