Returns to settlor?

What a difference a month makes. Last month I attempted a summary of how the proposals on the taxation of non-domiciled UK residents would significantly affect offshore trusts. Since the last article, we have now had the Budget, and the Government has pulled back some of the more draconian elements of its proposals. Briefly, the changes are as follows: - The settlor's charging provisions in s86 TCGA 1986 will not apply to trusts created by UK settlors. Previously, the proposal was to tax the settlor on UK gains on an arising basis, and on non-UK gains on a remittance basis. Now, the set...