TRS - Settlor under 18

There are people within HMRC who know a great deal about the law of trusts and their taxation. As an example the pages following CG65400 concerning PPR and common intention constructive trusts/ proprietary estoppel. It seems clear from the controversies over what trusts are excluded from TRS that those in HMRC instructing the drafter of Schedule 3A to SI 2017/692
were not among that august cadre. Nonsense in, nonsense out. Taxation or regulatory law that is applicable by reference to well-established legal concepts should be based on a solid jurisprudential understanding of them.

Jack Harper

Is not a part of the problem (if not the essence of it) that TRS stems from a European Directive?

Paul Saunders FCIB TEP

Independent Trust Consultant

Providing support and advice to fellow professionals

Mais Oui! ¥Claro que si! SelbstverstÀndlich! Certamente! Boutros Boutros Ghali! Eurononsense.

Jack Harper

“Eurononsense” perpetrated in part by HMRC and others who refused to have the trust correctly categorised and defined as a property law mechanism - a truth of which, incidentally the French were perfectly aware. Put prĂ©judice into any system, you get garbage out.