Readers' forum : Jersey distributions

A Jersey trust had only £10 in it until 2013 when one-third of the share capital of a Jersey-incorporated family investment company was transferred to it under the will of the mother/grandmother of the principal beneficiaries. The other two-thirds of the shares were passed into trusts for two other children of the settlor. The deceased settlor was never UK resident having always lived in Jersey. She inherited the shares from a brother who formed the company but who was not UK resident for many years before his death.

The UK-resident beneficiaries wish to realise their share of the Jersey company that holds a portfolio of UK quoted equities under discretionary management.

The trustees’ tax advisers say all the undistributed income from the formation of the company many years ago is assessable as relevant income under ITA 2007 s 731. They also advise that the distribution of the...