Author: David Rowell (2002)

David Rowell examines some recent developments which have turned the taxation of
non resident trusts into a minefield

(taken from Issue No 18 –  January 2002

Where trustees are not resident in the United Kingdom it would usually be difficult for the Revenue to recover tax from them and the capital gains tax legislation does not seek to impose liability on them. What can more easily be done is to charge tax by reference to the gains of the trust on the settlor or the beneficiaries, if he or they are resident here. From its earliest days the legislation has contained provisions for that purpose but, over the last four years, these have been made a great deal more stringent.