Readers' forum : Kiwi trust

My client and his wife were born in the UK. He left when he was three to live in New Zealand and his wife moved there as an adult. They set up a trust in NZ a few years ago after the sale of his business (he met his wife just before the sale). They are joint settlors of the trust. Now they plan to move back to the UK with their six-year-old daughter who was born in NZ. Aside from being settlors of the trust the husband and wife are trustees as is their NZ resident lawyer. They are also beneficiaries.

I understand that when they return to the UK in mid-2017 (just post-April 2017) they will be treated as immediately resident in the UK for tax purposes by virtue of the domicile of origin rules. I am uncertain as to the daughter’s...