Para. INTM 603400 of HMRC’s International Manual is entitled Transfer of assets abroad: Non-domiciled and deemed domiciled settlors from 6 April 2017: Exceptions to transactions ignored for tainting purposes.
The guidance has been updated as follows.
INTM 603380 looks at situations where transactions which added property or income to settlements were ignored for the purposes of tainting the trust.
INTM 603400 looks at a number of exceptions to the rules on ignoring such transactions. This page has been updated to make it clear that “the recipient of the loan must be the trustees of the settlement whose tainting position is being considered”.
Related content from Claritax Books
Advising British Expats is a detailed guide to the tax issues arising for individuals who leave the UK to live and work abroad. Written for accountants and other professional tax advisers, the book also includes commentary on individuals coming to work in the UK.
