Originally posted by THEPUMA
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April 2010 comes along and therefore the "scheme" is ineffective. What exposure does one have?
Is this an arrangement in accordance with the recent disclosure rules? Does this mean that HMRC could then attempt to go back to the start of the disclosure rules and charge the trust income to UK taxes ?
If so this is a fairly substantial risk - but on the other hand even with the anti avoidance legislation it would seem a bit perverse because the DTA was in force during the period it provided the benefit.
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