Tax Advisers' Guide to Trusts

Explores UK tax rules applicable to trusts resident in the UK or abroad, and the liabilities of trustees, settlors and beneficiaries. Substantial updates cover 2025’s once-in-a-generation legislative changes around non-dom rules.

This title is written to provide tax advisers with an understanding of the UK tax rules applicable to trusts resident in the UK or abroad, and the resultant tax liabilities of the trustees, settlors and beneficiaries, and opportunities for reducing those liabilities where possible.

As well as background to trusts and trustees' powers and duties, the commentary deals with the main types of private trusts and the rules that apply to them . There are also important chapters on residence and domicile and foreign trusts, charitable trusts, and purpose and heritage trusts. A number of specialist areas such as protective and vulnerable persons trusts are also dealt with.

This new edition covers the once-in-a-generation legislative changes which came into effect in 2025 concerning the removal of non-dom rules. These include:

- Abolition of domicile as a relevant factor in determining liability to inheritance tax, capital gains tax and income tax;
- Remittance basis of taxation removed for 2025/26 and later years, but previous untaxed amounts held overseas will be taxed when remitted;
- Liability to tax for 2025/26 and later years will be based on residence
- UK resident settlors of offshore trusts will be taxable on trust income/gains on an arising basis from 2025/26, as the “protected trust” regime which has applied since 2017 is removed;
- Offshore trusts settled by a non-UK domiciled settlor will be within the scope of inheritance tax if the settlor is a “long term resident” (LTR) of the UK.
- Change in CGT rate for trustees was announced in Budget - increased from 20% to 24%.
- The introduction of caps on Agricultural Property Relief (APR) and Business Property Relief (BPR).

A digital version of this title is available as part of our online tax resources.