Time Apportionment Relief

Hello,

I am looking for some advice on a current case that involves an Offshore bond and non-UK residents.

The Offshore bond was established in 26/06/2011 and put into a Spanish Trust with the clients as Trustees. The Trust was dissolved and the bond was assigned to the joint clients in 16/02/2021. The clients were Spanish residents from when the bond started until they moved back to the UK on 01/07/2022. In order to calculate the gain, I have been trying to calculate the applicable TAR.

Can anyone advise how TAR works when a bond is assigned from a Trust?

Thanks!

Comments

  • Who settled the trust - what was their position?

    Ws this a spanish compliant offshore bond that was purchased or an offshore bond that should have been only used for UK residents?

  • Wouldn't TAR only apply back to the point they actually owned the bond? i.e. from 16/02/2021? Or does the fact it is a pre-2013 contract mean different rules?

  • Not necessarily. It's very complicated - you need to know the answer to the two questions - they

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