Trustees of the P Panayi Accumulation & Maintenance Settlements v HMRC [2018] WTLR 1497
Winter 2018 #170In 1992 a Cypriot national, Panico Panayi, settled 40% of the shares of Cambos Enterprises Limited on the trusts of four Settlements for the benefit of his children and other family members. At the time the trusts were created, both the settlor and the trustees were resident in the United Kingdom. Subsequently, the settlor and his wife decided to return to Cyprus. On 19 August 2004 new trustees were appointed, all resident in Cyprus. As a result, a majority of the trustees ceased to be resident in the United Kingdom. When the trustees filed tax returns for the year 2004/2005, they failed...