A non-UK domiciled High Net Worth client approached us for tax advice on establishing a Family Investment Company in the run up to the changes to the long-term taxation of “non doms”, introduced on 6 April 2017.
The proposed tax changes introduced a window of opportunity whereby non-UK assets, in this case the client’s substantial investment portfolio in Guernsey, could be transferred to a newly incorporated private company prior to April 2017.
From 6 April 2017 onwards the client, as a newly deemed UK domiciliary, would have had to pay UK income tax and capital gains tax on investment returns accruing within the Guernsey portfolio. By transferring the portfolio to a Jersey company, of which the client would be a UK-resident director and shareholder, the future investment returns would arise within the company, with the corporate tax rates applying being significantly lower the personal tax rates.
We provided the tax advice, which included the provision of a bespoke share capital, which the client intends to slowly gift to his children as they grow older, thereby transferring wealth in a tax efficient way and gently introducing them to the responsibilities of managing the family’s personal wealth.
Furthermore, we provided full company secretarial support, by taking over the compliance and regulatory burden of operating the company, including minute taking and filings with regulatory authorities, so that the company was maintained in good standing and the client was free to focus on investment activities.
