In recent years, the crypto-asset sector has experienced considerable growth, significantly changing the world of payments and investments. However, it has also suffered from poor regulation at the European level, including from a tax perspective.
The regulation of crypto-assets has, therefore, been a major challenge for European governments, including tax authorities, to create a new international standard for the automatic collection and exchange of informatio...
In Grand View Private Trust Co Ltd v Wen-Young Wong [2022] UKPC 47 the Privy Council analysed the purpose of a trust considering the scope of powers given to the trustees and whether any exercise of those powers is for a proper purpose.
Background facts
The case concerns two Bermuda-based trusts set up by two brothers, YC and YT Wang (the 'Founders'), founders of the Formosa Plastics Group (FPG), a large conglomerate business in Taiwan.
The first trust (irrevo...
The Chancellor of the Exchequer, the Rt Hon. Jeremy Hunt MP, delivered Spring Budget 2023 to Parliament on 15 March 2023 and announced the following changes to trust taxation.
Low-income exemption
Currently, trusts that receive solely savings income in a tax year giving rise to tax of £100 or less (£500 for interest in possession trusts and £222 for discretionary trusts), have no reporting obligations or tax liability.
With effect from 6 April 2024...
What is a letter of wishes (LOW)?
A letter (sometimes called a memorandum) of wishes (the “LOW”) is a document written by the Settlor of a Trust and can be a very useful tool in helping the Trustees to manage and administer the trust - in particular it is a very common device when a discretionary trust is created.
A LOW provides guidance to the Trustees as to the manner in which the Settlor would like the trust fund to be administered for the benefit of their i...
The Register of Overseas Entities (ROE) came into force in the UK on 1st August 2022 and has been introduced by the new Economic Crime (Transparency and Enforcement) Act 2022.
Changes to the ROE mean that overseas entities who are existing registered proprietors of (or are proposing to become a registered proprietor of) a property or land in the UK (the “qualifying estate”) they must register with and will have to provide additional information to Companies Hous...
