The clients were non-UK-resident trustees of an offshore discretionary trust. We were instructed to review the tax treatment of the structure and its suitability for the family.
Our advice covered the following:
- The UK tax treatment of the trustees, the settlor and the beneficiaries
- The UK tax treatment of underlying holding companies and UK residential property held in the structure
- A cost/benefit analysis of whether to restructure and whether to bring the trust onshore