Since the original announcement made by the HMRC UK, on changes to the UK tax laws in 2015, a number of consultations, delays and further announcements were made throughout 2016 leading to indicate that the implementation of the changes will happen on 6 April 2017.
This caused a rush of planning for possible re-structuring by many consultants in 2016. Subsequent political factors further delayed the implementations and an announcement was made in September 2017 that the changes will take effect retrospective from 6 April 2017.
Whilst a number of factors are still being clarified, the takeaway points from the talk by Mr. Nick Jacob - Partner, Private Client, Fosters were:
- Non domicile residence will be considered as Deemed domiciled from the 15th year of residence in the UK, thus be liable to world-wide tax basis
- To review possibilities of creating new trusts or adding assets into existing trusts before being deemed as domicile, so that UK Inheritance Tax (IHT) matters can be addressed
- NOT to add in any further assets into the trust after being deemed domiciled
- To keep good records of all acquisition costs and values and to make election in year of disposal
- Trust is still a good planning tool
- To be careful of tainting the trust e.g. loans must be with commercial interest rate
- There are new rules on valuation of benefits
- For UK residential property owned under a company or partnership no longer protected from UK IHT
- Anti-avoidance provision will catch any arrangements to avoid IHT
43 attended the talk, most were from the banking and trust industry.
Click HERE to view event photos.
Ms Linda Wong
Managing Director, Kensington Trust Singapore Limited