I have been speaking to a prospective client who has transferred a property to a bare trust for his grandchildren. They are currently aged three and five and are resident in Sweden. Neither has ever lived in the UK but their father is a UK citizen.
As EU citizens the grandchildren are currently entitled to the personal allowance each year in the UK which covers the income arising. However I have not been able to find any advice on what happens to personal allowances after Brexit. I am assuming that the allowance continues to apply until the UK eventually gets around to reviewing those rules.
If the allowances are no longer available to EU citizens would the minor children qualify for the personal allowance on the basis of their father’s citizenship in line with the domicile rules? Alternatively would they be denied the...
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