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A significant number of our clients are resident or domiciled outside the UK, or otherwise have existing interests in offshore trusts. This can give rise to extensive tax planning opportunities. With careful use of offshore structures, it is often possible to defer or avoid liability to income tax, capital gains tax and inheritance tax.
Inward investors, ie individuals moving their wealth and (possibly) themselves to the UK for the first time, can be advised upon the setting up of offshore settlements to hold cash and investments, with, in many cases, an offshore company interposed to hold any UK land. Advice will be given on steps to be taken to avoid income tax charges on the use of UK domestic premises and the use of loans to reduce income tax on commercial rent.
UK resident but non-domiciled individuals can structure their offshore assets in a way that enables them to take advantage of the remittance rules which allow income tax and capital gains tax to be deferred indefinitely. We will also advise these individuals on ensuring that they have only minimal UK situs assets in order to mitigate exposure to inheritance tax. Establishing offshore settlements can result in the complete avoidance of capital gains tax while the settlor remains non-domiciled.
Individuals engaged in personal international business use us to engage in tax efficient onshore and offshore structuring to avoid tax in the UK and elsewhere while at the same time being compliant with OECD and EU regulations.
UK residents planning the sale of major capital assets might contemplate becoming non-resident to avoid capital gains tax. We guide these clients through this complex area to take full advantage of UK legislation and international double taxation treaties. We also use our extensive contacts in other jurisdictions to make sure that the client does not become subject to taxation elsewhere.
Beneficiaries of offshore trusts need to take care that such tax advantages as may exist are not lost through inappropriate application of trust funds, but at the same time we will suggest restructuring, repatriation or even the winding up of such trusts if this is the cost effective option or is otherwise in our client's best interest.