Are there any CGT consequences of repatrioting a pre 1991 offshore trust. The offshore trustees would resign and UK trustees would be appointed. What are the CGT consequences and would any rolled-over gains be crystalised ?
patricia graham
Replies (4)
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Could you repost this query with more information?
For example is the settlor a beneficiary, an outline of the trusts investments etc.
Professional Advice
If I were in your position, I'd seriously consider using a 3rd Party specialist.
Offshore trusts are an area where it is too easy to run into a negligence claim if you don't know what you're doing.
Foreign Trust becoming UK resident trust
Patricia,
As I understand it your question is about a foreign trust which wants to become a UK resident trust. this being the case, the gain heldover when the trust was first created would not be chargeable until the underlying assets are disposed off. this is the simplest answer you can have because the trust is actually putting itself under the jusrisdiction of UK Revenue Law and so there can't be any penalty for doing so. Unless I have misunderstood your question about a UK trust emigrating then please let me know.
Best regards,
Jay Tanna