Unauthorised Unit Trusts (“UUTs”) - Mazars - United Kingdom
Unauthorised Unit Trusts (“UUTs”)
HMRC has announced new measures to put an end to a corporation tax avoidance scheme involving UUTs. The scheme operated where a UUT received foreign income net of withholding tax and subsequently claimed a credit and resulting repayment of tax from HMRC where no tax had been or would be paid by the UUT.
Draft legislation was published in November 2009 and following a consultation process HMRC has made minor amendments, limiting the effect on unit holders, before publishing the legislation in final form.
The changes in legislation will cause a beneficiary receiving a UUT distribution paid out of overseas income on which UK tax has been reduced by double tax relief to have the distribution taxed as overseas income.
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- Copyright 2012 - Mazars - United Kingdom
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- Copyright 2012 - Mazars - United Kingdom
