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Offshore FURB

18 July 2007
Issue: 4117 / Categories: Forum & Feedback

My clients (UK resident and domiciled) set up an offshore FURB (Jersey) in May 2000. Shares (value £200,000) owned by their UK trading company were transferred to it and PAYE and NIC was paid. The shares were sold in 2002 for £400,000. The FURB trustees created an offshore limited company owned by the firm and lent it £250,000, which was used to buy a UK residential property. The company plans to demolish it and construct a small block of flats (using borrowed money) to be sold with the intention of making a profit. My questions relate to the UK tax treatment on these proposals.

My clients (UK resident and domiciled) set up an offshore FURB (Jersey) in May 2000. Shares (value £200 000) owned by their UK trading company were transferred to it and PAYE and NIC was paid. The shares were sold in 2002 for £400 000. The FURB trustees created an offshore limited company owned by the firm and lent it £250 000 which was used to buy a UK residential property. The company plans to demolish it and construct a small block of flats (using borrowed money) to be sold with the intention of making a profit. My questions relate to the UK tax treatment on these proposals.
What are the UK tax implications if the FURB is wound up and the proceeds are paid to the UK clients?
Is there an age limit on which my clients can take the benefits of the offshore FURB?
Does it save UK tax if they...

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