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Pre-April 2017 Trusts For Non-UK Domiciled Individuals

5 January 2017

As you may know the much publicised and significant changes to the UK taxation of non-UK domiciled individuals their estates and their offshore structures are expected to take effect from April 2017.

While the format of the proposed changes is now becoming clearer at PraxisIFM we are mindful that the non-UK domiciled community currently face a dilemma with two options available to those individuals affected:

Option 1 Review and restructure affairs now (with associated costs) to ensure restructuring is implemented before April 2017. There is a risk of incurring significant costs for structuring which may ultimately not be needed when viewed in the context of the final legislation as enacted; or

Option 2 Wait until the legislation is finalised in the hope that any restructuring opportunities presented can be evaluated and implemented in a short window between finalisation of the legislation and 5 April 2017.

The lead time needed to create a Trust structure capable of receiving substantial and diverse assets has increased primarily due to initial customer due diligence requirements placed on Trust Service Providers and other financial institutions by our regulators.

At PraxisIFM we believe that those choosing the Option 2 outlined above run a significant risk of being unable to implement the required restructuring of their affairs in time.

Equally we are mindful of the dilemma faced by those who do not wish to undertake full restructuring until the full extent of the proposed changes are known.

With this in mind PraxisIFM have developed the Pre-April 2017 Trust which allows those who may be affected by the 2017 changes to establish a simple discretionary trust at a minimal cost and settling an Initial Trust Fund which can be as small as 100.

PRE-APRIL 2017 TRUST KEY FEATURES
  • Simple discretionary trust established with a standard template deed single settlor and single beneficiary;
  • Low initial cost to cover fees and costs of establishment together with a small Initial Trust Fund;
  • Client due diligence completed and Trustee bank account opened in readiness for final legislation being released;
  • Clients well positioned to settle assets onto trust quickly when legislation finalised; or
  • If no further assets should be added to the Trust then the Trust will fail on 6 April 2017 at no further cost.
FOR MORE INFORMATION CONTACT:GUERNSEYSteve CliffEmail: steve.cliff@praxisifm.comTel: +44 (0) 1481 737606JERSEYLiz NurseyEmail: liz.nursey@praxisifm.comTel: +44 (0) 1534 835858MALTAMatt NellEmail: matthew.nell@praxisifm.comTel: +356 2546 8225SWITZERLANDCaroline Bennett-AkkayaEmail: caroline.bennett-akkaya@praxisifm.chTel: +41 (0) 22 715 1452

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