Where the settlor is domiciled in the UK, any foreign assets are
included in the trust are taxed in the normal way.
DTR might be available against lifetime transfers into trust, but not on discretionary trust charges. ( IHTM27185)
If the taxpayer claims that the trust is exempt or partly exempt
because of the domicile of the settlor, review the appropriate
schedule in the account and refer to TG as appropriate. (
The next page gives some details of the impact of overseas domicile. General domicile details are at the domicile section of this manual. ( IHTM13000)
If the trustees are not in the UK, refer to Litigation immediately, even though the trust itself may be a normal UK trust.
Use of foreign trusts is a very well used method of avoiding tax
generally, not just inheritance tax. Discuss any suspected
avoidance measures with your manager or with TG.
Review the IHT Financial and Economic Awareness intranet site for new avoidance schemes.