Need clarification on the 10 Year Anniversary Trust Tax charge. If you have offshore Trustees, with offshore settlor and beneficiaries are their UK situs assets still subject to the 10 year anniversary Trust Tax charge?
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10 year charge
Where trust assets are sited directly in the UK - rather than being held through non UK incorporated companies [ or through companies with bearer shares where the trustees kept the share certificates in the UK ] - then the trustees regardless of their residence or the residence or domicile staus of the settlor or the beneficiaries are indeed subject to the 10 year charge. If the settlor had been non domiciled at the date of the settlement only UK situs assets are taken into account
The only exception would be if on the decennial anniversary there was a Transitional Serial Interest in the property concerned .
10 year charge
Does non domicile exclude deemed non for IHT. But at time of settlement non dom for Income Tax purposes?