International aspect of bare trust

[maggiefleming]

A new client of mine is divorcing. As part of the settlement, her husband wishes to set up a bare trust for the minor children to pay their school fees. He is non-domiciled and non-resident. Am I correct in thinking that all the income of the trust will be assessed on him despite his residence status? I do not know at this stage the extent of his UK source income. Does anyone know of any pitfalls I should be aware of when selecting investments for the trust? What would happen if we chose an offshore investment such as a roll-up fund or a bond, for example? I believe I have read in the past that, if an offshore bond is used and the settlor is non-resident, the trustees are assessed at the rate applicable to trusts, even where the trust is a bare trust.
All help gratefully received.

[maths]

Am I correct in thinking that all the income of the trust will be assessed on him despite his residence status?

No; non-UK source income will not be assessable on the settlor. UK source income may be subject to income tax on the settlor depending upon the type.

Probably preferable to avoid UK source income to avoid UK tax problems.

Offshore bond feasible particularly if the 5% withdrawal facility is enough re school fees.

As the trust is non-resident, settlor is non-resident and bond offshore then trustees not liable to UK tax and neither is the settlor on any chargeable event.

My concern is whether any of anti-avoidance provisions apply as and when trust monies applied in providing kids with a benefit.