This guidance note details how UK resident settlors of non-resident trusts are taxed in the UK before 6 April 2025. The abolition of the domicile rules and remittance basis rules mean that the treatment after this date is different.
Where a UK resident settlor has created a non-UK resident trust, they may become personally liable to income tax or capital gains tax in relation to the trust’s income or gains, even if they do not receive a payment from the trust. The following legislative provisions levy a potential charge on UK settlors of non-resident trusts:
the settlements code set out in ITTOIA 2005, ss 619–648 imposes an income tax charge on settlors with respect to income arising within a ‘settlor-interested’ trust. The provisions apply equally to UK resident and non-resident trusts
the transfer of assets abroad code (TAAC) set out in ITA 2007, ss 714–747 imposes an income tax charge on settlors who may benefit from a non-resident trust as a result of a ‘relevant
Company carsIntroductionCompany cars are one of the most common taxable benefits. The rules for calculating the benefit are complex, and the reporting requirements are more onerous than most benefits. Company cars are covered by very specific legislation. Detailed guidance on each of the following
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Capital allowances on carsSummary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions of 50g/km and below 18%CAA 2001, s 104AASecondhand cars with CO2