KEY POINTS
- Non-resident companies' capital gains will be taxable on UK resident shareholders
- Offshore funds which qualify for distributor status may have to follow new reporting rules
- Clear legislation on residence would be welcome
A number of offshore-related changes to UK legislation were contained in both the 2008 Budget and the Finance Bill. There had been much trailing of changes to the way that non-domiciliaries are taxed. These were followed by suggestions draft legislation and then a Finance Bill.
The Bill pulled back from some of the earlier proposals which had been suggested regarding the way that non-domiciliaries who are resident in the UK are taxed. (See my articles Domicile and residence and A lot of thinking to do! for consideration of these various proposals.)
The non-domiciliary changes are not the only implication for offshore trusts as there are...
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