FAQ: Residence and domicile - disclosure

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HM Revenue & Customs (HMRC) said it will not require disclosure of the source of funds remitted from offshore trusts to non-domiciled beneficiaries, using the remittance basis if the remittance is taxed in full. Does this mean that HMRC will not open any enquiries into the tax affairs of non-domiciled beneficiaries?

No. Clearly HMRC will always have the right under the Self Assessment regime to enquire into a person’s tax return to ensure the right amounts have been declared and the right tax paid.

HMRC says it will not require disclosure of the source of funds remitted from offshore trusts to non-domiciled beneficiaries using the remittance basis if the remittance is taxed in full. Does this mean that HMRC will not open any enquiries if the remittance is returned as a capital gain rather than income?

No. Clearly HMRC will always have the right under the Self Assessment regime to enquire into a person’s tax return to ensure the right amounts have been declared and the right tax paid.