These changes are wide ranging. Trustees, beneficiaries and in some circumstances settlors, of non-UK resident Trusts should seek advice as to whether and to what extent they will be affected.
The delay in the proposed implementation of the anti-avoidance provisions is very welcome and provides a limited window of opportunity to mitigate UK tax exposure before 6 April 2018.
The changes effective from 6 April 2017
The proposed changes effective from 6 April 2018