Editorial |
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| Authors: | Molloy Tony; Graham Toby |
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| Institution: | Correspondence: *Tony Molloy QC, Shortland Chambers, Auckland, Email: apmolloyqc@shortlandchambers.co.nz Toby Graham Farrer & Co, London, Email: tbg@farrer.co.uk |
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| Abstract: | The changes to the UK tax rules on residence and domicile havebeen well publicized. Amongst other things, the new legislationremoves the shelter from capital gains tax which was previouslyprovided to UK non-domiciled individuals who benefited froman offshore trust. Some of the harsher (and more retrospective) aspects of thedraft legislation published in January have since been tempered.Offshore trusts will still have a role in planning for non-domiciliaries,not least because significant inheritance tax advantages remain.However, the way in which the process has been managed by theGovernment and HM Revenue & Customs leaves trustees andadvisers (still getting to grips with the 2006 changes to thetaxation of trusts) with little confidence that |
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