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OFFSHORE TRUST REFORMS: Reform in practice

18 April 2017  

Emma Loveday provides some specific examples of the effects of recent reforms to taxation on non-UK domiciled trusts

In the March 2017 edition of Trusts and Estates Law & Tax Journal, I wrote an article entitled ‘Where are we now?’ providing an update on the various government consultations affecting private client practitioners. The consultations included those relating to the reforms to the taxation of non-domiciliaries (non-doms) which came into force on 6 April 2017. In this addendum to the article, I explain in further detail how these non-dom reforms will affect a standard offshore trust structure by looking at two different scenarios before and after 6 April 2017. Since writing the original article, the government has published amendments to the non-dom reforms in Finance Bill 2017, and this addendum incorporates those changes.