The main benefits for an individual, who is becoming UK deemed-domiciled on 6th April 2017, of transferring assets into any of a
are the following:
1. Subject to any UK IHT Charge which may be leviable in respect of individuals who are already deemed-domiciled for IHT purposes (see ‘Bourse Info Sheet – Special Considerations for IHT Deemed-Doms’ for further information), there is no UK tax charge in respect of the transfer of any assets into any of the above.
2. All income and gains arising in any of the above will be ‘rolled up’ offshore within the product with UK tax only payable when sums or assets are paid out or benefits made available to close family members resident in the UK. For an outline of the new taxation regime relating to offshore trusts, see here. Further, any reporting under HMRC’s Self-Assessment regime will be limited accordingly.
3. To the extent that the UK deemed-domiciled individual opts to leave the UK, any structures comprising the above Bourse products or entities (with the exception of the QNUPS) are relatively straightforward to unwind with assets capable of being returned to the ownership of the individual (or his/her nominee).
Bourse 2017 Nom-Dom Solution
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