Decision Analysis for 2017 Deemed-Doms

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.

Do I have offshore assets which I wish to shelter from IHT, IT and CGT? Please see Advantages for Deemed-Doms of maintaining assets in an offshore structure.

There is no need to retain your offshore assets inside an offshore structure.

Yes

Am I deemed domicile for IHT purposes (i.e. have I been UK resident for 17 of the last 20 years?

Yes

Please see Special considerations for IHT Deemed-Doms.

Do I have “clean capital” which is maintained offshore? Please see Overview of Clean Capital.

Yes

Clean Capital is capable of being contributed to a Trust, Bond or Annuity and should give rise to a tax-free return of capital into the UK.

Within my offshore assets, do I have mixed income and capital held in (or can be liquidated into) cash that I may be able to separate in future? Separating out Clean Capital from Mixed Funds.

Yes

Mixed funds should be separated from clean capital though remain capable of being held in a Trust, Bond or Annuity but all monies coming out will be subject to tax if monies going in contained income and/or gains.

Within my offshore assets (whether clean capital or mixed funds), do I have cash or non-highly personalised investments?

Yes

These assets are capable of being held in an offshore Bond. Please see Advantages of establishing a Bourse Executive Investment Bond.

Do I need access to my funds as a pension?

Yes

You could buy either a Advantages of a Bourse Living Annuity or a Advantages of having a Bourse QNUPS.

A Bourse Protected Trust will give you control over the timing of remittances and shelter/defer IHT, IT and CGT as well as managing compliance and reporting. Please see Advantages of settling a Bourse Protected Trust.

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Bourse 2017 Nom-Dom Solution

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