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Volume 479: debated on Thursday 17 July 2008

To ask the Chancellor of the Exchequer what assessment (a) he and (b) HM Revenue and Customs have made of the implications for the Exchequer of new forms of trust created by the states of Jersey and other tax jurisdictions since 2005; and what representations the Government have made in response. (219799)

The question of whether the income and gains of a trust are liable to United Kingdom taxes depends on a number of factors such as whether the trustees are treated as being resident in the United Kingdom for tax purposes, what connection the settler has to the trust, and what the beneficiaries of the trust are entitled to under the terms of the trust. The particular structures provided for by non UK law do not determine residence or chargeability to UK tax and HMRC has not carried out detailed analysis of these particular types of trust.