TOAA & the Settlements Legislation - A Bite-Sized Guide

Introduction

The transfer of assets abroad (‘TOAA’) legislation and its often-overlooked companion, the so-called settlements legislation, together contain an impressive array of anti-avoidance legislation designed to prevent the use of offshore trusts, companies, and other entities to avoid liability to UK income tax.

These complex and often overlapping provisions must always be considered when you are advising clients on cross border matters, as a failure to do so can lead to unfortunate consequences for the advisor as well as the client.

This short webinar is aimed at professionals who advise in international taxation, or whose work is in a related field, such as trustees, bankers, and financial advisors.

It will take you through the main characteristics of the regimes, where they apply and how they can be avoided.

Crucially, it will also look at how the two regimes interact and, sometimes, overlap.

What You Will Learn

This webinar will cover the following:

• Main features of TOAA and Settlements Code; how they compare and contrast
• Main issues for settlors/transferors in respect to offshore trusts, foundations, and other structures
• How are foundations treated?
• How the remittance basis interacts with these regimes and the impact of the protected foreign source income rules
• Problems and opportunities with loans to and from structures
• How benefits received from trusts and other structures are taxed
• How UK source income is taxed when received offshore

This webinar was recorded on 22nd September 2022