Time Apportionment Relief
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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