UK Offshore Trust, Tax Relief

[Metalic]

I have a UK beneficiary offshore trust who is in receipt of capital payment. The UK beneficiary is charged to UK capital gains tax on the capital payments insofar as they are matched with stockpiled gains within the Offshore Trust and a supplementary charge paid by the beneficiary where applicable.
The offshore trust pays US capital gain tax while it is USA residential trust. Is there any type of tax relief the beneficiary can claim against his UK tax liability in respect of the tax paid in the US on the gains?

If an individual sells a shareholding in the US and suffers tax in the US, under the double tax agreement, the individual is able to claim relief for the US tax suffered against his UK CGT liability. Are there similar provisions where an offshore trust structure is involved, otherwise the gains are effectively being taxed twice, once in the hands of the offshore Trustees and then again in the hands of the UK beneficiary.

Please help me with this...thanks.

 

[clemens]

Usually if you structure Things right for instant with an Seychelles Trust you will only have to pay tax if you receive funds from the Trust to your normal bank account in your current country.

 

[Jack Dui]

Both examples 1 and 2 on HMRC help sheet HS261 show foreign tax credits against attributable gains.

Depending on the circumstances, either the foreign tax can be claimed as above, or used to reduce the gains (sometimes easier if that brings a gain just above the annual exemption to being just below it).
Please check out the link for more details

Non-resident trusts - Detailed guidance - GOV.UK

 

[MiltonStone]

Would the tax question only apply if the real owner of the Trust is known the the IRS, HMRC or whatever the tax office in a country is called?

 

[negon]

You forget about TIEA and other agreements they have in place in Europe and the UK! forget about UK and US as a part of any offshore structure it won't work without a very good tax lawyer and accountant.

 

[Cyrus05]

Is it still a good choice to put your trust in United Kingdom after what they did in their membership in European Union? I might have to think again after they account their decision to leave