Australian Company Trust - tax in UK

Trusts Discussion
1

Hi there -

Question regarding an Australian Company, that owns an Australian Family Trust, that in turn owns a rental property in London.

Dividends are distributed to Australian based beneficiaries.

HMRC doesn’t have a category for this - as it’s not a UK based trust, they seem to come up blank.

Does anyone have any ideas how to deal with the HMRC potential tax liabilities?

Thanks in advance
Annie Kerrigan
Cobalt Place Company Trust

2

It may just be me but I think you need to be a bit clearer.

The Australian Trust owns a UK rental property, that’s straightforward. I assume it is a discretionary trust for beneficiaries resident in Australia.

Is the Australian company the trustee of the trust?

Are any of the beneficiaries UK domiciled (UK origin - moved to Australia)?

Andrew Goodman
Osborne Clarke LLP