I have been asked whether an Offshore trust will have any UK IHT issues and have been completely stumped by the question.
The Trust has been set up in the BVI by a Non-Domiciled, Non-Resident individual.
It is managed by a Trust company resident in BVI.
The Trust's only asset is 100% of the share capital of a BVI company (company A).
That BVI company owns 100% of the share capital of a further BVI company (company B).
Company B owns residential properties in the UK which it rents out on normal commercial tenancies (not to anyone connected with any of the companies or the trust).
The Trust will not receive any rental income, it will receive dividends from Company A which in turn will receive dividends from Company B.
My concerns are whether the Trust Will be subject to Periodic and Exit charges and whether there are any other IHT implications I am missing.
Any help would be greatly appreciated, even if it is just pointing in the right direction of where to find the answer.