Non-UK resident beneficiaries are not subject to capital gains tax on trust gains. Capital gains taxĪt present, gains realised by trustees are attributed to beneficiaries who receive a benefit from a trust whether the beneficiary is resident or non-UK resident. As the legislation is long and complex, some of the expected provisions were postponed and are due to take effect from 6 April 2018.
However, the Government promised, as part of the changes to the tax rules for non-UK resident trusts, to try to close perceived loopholes. The majority of the expected changes to the taxation of non-domiciliaries which were first announced in July 2015 were passed into law in November 2017, with retrospective effect from 6 April 2017.
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