Managing Risk in Cross-Border Tax - TOAA, FIG & More

Introduction

This practical, in-person update session will provide accountants, tax advisers, and legal professionals with an overview of key developments in UK international tax.

Presented by Shanzé Shah, barrister at Old Square Tax Chambers, the session focuses on two areas that continue to present significant advisory and compliance challenges: the operation of the Transfers of Assets Abroad (TOAA) provisions following Fisher and the introduction of the new Foreign Income & Gains (FIG) regime.

Rather than treating these topics in isolation, the session will explore how they interact in practice, particularly in the context of offshore structures, legacy planning, and HMRC scrutiny. The course will conclude with a timely round-up of recent and emerging tax developments, ensuring you leave with an up-to-date understanding of the current risk landscape and practical takeaways you can apply immediately in your advisory work.

What You Will Learn

This course will cover the following:

• TOAA - Post-Fisher
• A practical recap of the TOAA rules, designed to refresh core principles and highlight where risk remains following recent case law:
• A clear overview of the statutory framework and policy intent behind TOAA
• Key principles clarified by Fisher and how they affect current analysis
• Understanding control, enjoyment and benefit in practice
• Common structuring issues and scenarios that continue to attract HMRC challenge
• Practical risk areas for advisers when reviewing existing arrangements
• The New Foreign Income & Gains (FIG) Regime
• An accessible explanation of the new regime, with a particular focus on real-world advisory and compliance considerations:
• The background to the FIG regime and what it is intended to achieve
• Key features of the new rules, including scope and eligibility
• How the FIG regime applies to offshore trusts, companies, and mixed structures
• Transitional issues and early-stage planning considerations
• Compliance obligations and areas of potential adviser exposure
• Recent and Interesting Tax Developments
• A concise and practical update on developments shaping the wider tax environment including:
• Selected recent cases
• Legislative changes
• Emerging areas of dispute
• What these developments mean for advisers in the short to medium term