Decision Analysis for 2017 Deemed-Doms – Cash

Bourse Trust Company and its joint licensees are licensed by the Guernsey Financial Services Commission under The Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 as amended.

Bourse Life and Pensions Limited is licensed by the Guernsey Financial Services Commission to carry on long term insurance business pursuant to the Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended

Bourse Corporate Services (Malta) Limited is registered by the Malta Financial Services Authority as a company service provider pursuant to the Company Service Providers Act 2013.

Bourse Pension Administrators (Malta) Limited is licensed by the Malta Financial Services Authority as an administrator for personal retirement schemes pursuant to the Retirement Pensions Act, 2011.

From 6th April 2019 all interest arising in the name of an individual who is UK Deemed-Domiciled must be included on his/her self-assessment tax return, regardless of in what jurisdiction the account is held, and will be subject to UK Income Tax.

However, payment UK Income Tax arising on the interest can be deferred and reporting obligations managed by putting cash into either

A Bourse Protected Trust; or
A Bourse Offshore Insurance Bond.

The following decision analysis is intended to assist any UK Deemed-Domiciled with the decision as to which of these structures to use.

CASH DECISION ANALYSIS

Do I have cash I want to leave outside the UK?

You should remit to the UK to be subject to UK Income Tax.

Yes

Do I have 'Clean Capital' which I can identify before 5th April 2019? Please see Separating Out Clean Capital From Mixed Funds.

You can shelter future income and gains and IHT in either a Advantages of settling a Bourse Protected Trust or a Advantages of establishing a Bourse Executive Investment Bond – though all payments out will be taxable.

Yes

Am I likely to invest in highly personalised assets?

Use the cash to pay the premium for a Advantages of establishing a Bourse Executive Investment Bond.

Yes

Settle the cash into a Advantages of settling a Bourse Protected Trust which allows for the selection of highly personalised assets (e.g. private company shares, property etc.)

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