Alice Martin, Elena Dunn and Carolyn Steppler write for Tax Journal on the UK tax implications of loans from non-UK resident trusts
min readPrivate Client Partner Alice Martin, Counsel Elena Dunn and UK Tax Advisor Carolyn Steppler have authored an article in Tax Journal examining the UK tax implications of loans from non-UK resident trusts.
The piece highlights how loans from trust structures, often seen as a straightforward way to provide liquidity to beneficiaries, can in practice carry significant and sometimes unexpected UK tax risks. The authors explore a range of common pitfalls, particularly in light of recent changes to the UK tax regime affecting offshore trusts.
They emphasise that trustees should not treat such loans as routine, noting that factors such as the purpose of the loan, the terms on which it is made, and the way in which funds are ultimately used can all have important tax consequences.
The article also outlines the practical steps trustees and advisers should consider before entering into loan arrangements, including ensuring appropriate documentation, commercial terms and a clear understanding of how evolving UK tax rules may apply.
Read the full article in Tax Journal.
