Wills & Trusts Law Reports | Summer 2018 #172Facts
DS and IS were at all material times resident in the UK for tax purposes and were beneficially entitled to the income from MOH, an English property development company of which they were the shareholders and directors. On advice, they used a tax avoidance scheme that took advantage of the provisions of the 1955 UK-Isle of Man double tax treaty (DTT). These provisions exempted the industrial or commercial profits of an Isle of Man (IOM) enterprise, which could include a partnership, from UK tax unless it was engaged in trade or business in the UK through a permanent establis...
Anthony Nixon, Martin Cross and Clementine Burch provide an update on ‘charitable purpose’ outside the UK and the IHT exemption ‘It is clear from other case law that “charitable purposes” could be carried on anywhere in the world, even though this was not stated in the Charities Act 2006.’ The late Beryl Coulter’s executors have …
Continue reading "IHT: Charity begins at home?"
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Simrun Seehra looks at IHT exemptions on gifts to charity, with reference to Routier ‘It is clear that the relief to an EU charity should not be refused provided the relevant conditions are met and the taxpayer is able to provide sufficient evidence.’ Lawyers in the wills and estate planning field commonly advise their clients …
Continue reading "Tax Relief: Consider jurisdiction"
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