Hi All
I am not sure if anyone will be able to help with this query.
I understand that the Finance Bill 2017 was going introduce rules to combat UK beneficiaries receiving a payment from a foreign trust tax-free, where that payment comes through a non-UK resident by way of a gift i.e. a distribution is made from a foreign trust to a non-UK resident beneficiary who then pays the funds (or part thereof) on to a UK-resident by way of a gift. As the payment from non-UK resident to UK resident is a gift, it is not taxable.
The idea of the new legislation being that the UK-resident recipient would be liable to income tax on the distribution as if the distribution had been made directly from the trust to the UK resident.
It seems that this has been dropped from the Finance Bill 2017 and most commentators seem to think this rule will only be brought into force to apply as of April 2018. Assuming this is true, is it the case that the current state of the law would mean that, in the scenario described in my first paragraph, the ultimate UK recipient would face no tax liability as a result of the gift payment ?
Thanks for reading
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