Classing non-resident company receipts

Many offshore structures include at least one non-resident company. Receipts received from these are not always easily identifiable as income or capital. In trust terms, understanding the nature of these receipts received is key to ensuring the receipt is dealt with in accordance with the terms of the trust. In tax terms, understanding the nature of receipts from non-resident companies is important so that trustees can determine whether a receipt might be received as potentially taxable income. The classification of receipts received from non-resident firms is governed by extensive cas...