Tax Planning for Non-Domicilliaries

Speakers

• Giles Clarke: author of Offshore Tax Planning 15th Edition
• Simon Jennings: partner Rawlinson and Hunter
• Emma Chamberlain: barrister 5 Stone Buildings
• Arabella Saker: partner Allen & Overy
• Dougal Powrie: technical director One E Tax Ltd
• Neil Manalay: Director Barclays Wealth advisor

OIGs and the transfer of assets code

For the purposes of the transfer of assets code (TA 1988 s 762ZA(1)) Offshore Income Gains (OIGs) are deemed to be the income of the trust noted Giles Clarke.

In the absence of any provision to the contrary the primary and secondary rules would result in many OIGs being taxed twice. So rules are provided to deal with these situations.

1. (An OIG matched with a capital payment under the primary rule cannot...