Pre-April 2017 Trusts For Non-UK Domiciled Individuals

Thursday 5 January 2017|Private Wealth
HomeNews & ViewsPre-April 2017 Trusts For Non-UK Domiciled Individuals

As you may know, the much publicised and significant changes to the UK taxation of non-UK domiciled individuals, their estates and their offshore structures are expected to take effect from April 2017.

While the format of the proposed changes is now becoming clearer, at PraxisIFM we are mindful that the non-UK domiciled community currently face a dilemma, with two options available to those individuals affected:
Option 1 Review and restructure affairs now (with associated costs) to ensure restructuring is implemented before April 2017. There is a risk of incurring significant costs for structuring which may ultimately not be needed when viewed in the context of the final legislation as enacted; or

Option 2 Wait until the legislation is finalised in the hope that any restructuring opportunities presented can be evaluated and implemented in a short window between finalisation of the legislation and 5 April 2017.

The lead time needed to create a Trust structure capable of receiving substantial and diverse assets has increased primarily due to initial customer due diligence requirements placed on Trust Service Providers and other financial institutions by our regulators.

At PraxisIFM we believe that those choosing the Option 2, outlined above, run a significant risk of being unable to implement the required restructuring of their affairs in time.

Equally, we are mindful of the dilemma faced by those who do not wish to undertake full restructuring until the full extent of the proposed changes are known.

With this in mind, PraxisIFM have developed the Pre-April 2017 Trust which allows those who may be affected by the 2017 changes to establish a simple discretionary trust at a minimal cost and settling an Initial Trust Fund which can be as small as £100.


  • Simple discretionary trust established with a standard template deed, single settlor and single beneficiary;
  • Low initial cost to cover fees and costs of establishment together with a small Initial Trust Fund;
  • Client due diligence completed and Trustee bank account opened in readiness for final legislation being released;
  • Clients well positioned to settle assets onto trust quickly when legislation finalised; or
  • If no further assets should be added to the Trust then the Trust will fail on 6 April 2017, at no further cost.


Steve Cliff
Tel: +44 (0) 1481 737606

Liz Nursey
Tel: +44 (0) 1534 835858

Matt Nell
Tel: +356 2546 8225

Caroline Bennett-Akkaya
Tel: +41 (0) 22 715 1452

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