Now that the dust is starting to settle on the Finance Act 2025, trustees, settlors and beneficiaries are getting to grips with what this may mean for the future of offshore trusts with UK domiciled (or in newspeak, long term resident) clients.
Up to 5th April 2025, trustees will have been thinking through whether they needed to realise income and gains pre tax year end, and whether they could trigger an internal rebasing of trust assets.
Now, as we look ahead to the new tax year, the next questions will be around the wholesale future of the trusts. Will it be wound up using TRF? Will the trust continue but possibly with some restructuring? Should the settlor be excluded? These are all issues that we are currently working with clients to advise on.