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OWEN CLUTTON argues that the new 'permanent establishment' test for trustee residence in TCGA 1992, s 69(2D) is too onerous.
KEY POINTS
- The previous residence rules for trusts.
- The new test for income tax and capital gains tax purposes.
- The effect of acting through a branch agency or permanent establishment in the UK.
- The effect of the wide meaning of the terminology.
- Does this mean that non-UK trust business will be lost to the UK.
AS PART OF the trusts modernisation programme the definition of trustee residence for both income tax and capital gains tax purposes was recast. This was done in FA 2006 although the part which defined where trustees are tax resident only took effect from 6 April 2007.
In broad terms the income tax definition was adopted but with certain modifications. It has become clear that there are aspects of the new...
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