I’m finding it difficult to find confirmation of the situation regarding discretionary trusts set up before 2006.
In summary, I have a client who set up a discretionary trust in 1987 (broad discretionary trust, definitely not an A&M). As I understand it, the trust has potentially been liable to anniversary charges in 1997, 2007, and 2017. The client’s previous advisers were of the firm view that an anniversary charge could only arise after 2006. I thought the FA2006 simply brought certain trusts within the already operational relevant property taxation system, and that a broad discretionary trust was already subject to that system?
Can anybody confirm this for me?
Port Worth Law