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An IFA recently had a query as to the UK tax treatment of an offshore bond held by an offshore holdin...

An IFA recently had a query as to the UK tax treatment of an offshore bond held by an offshore holding company. The main points to consider in relation to the above question will be when was the bond effected and what is the residence and domicile status of the beneficial owners of the company. The following assumes that the offshore company is structured in such a way that the company is managed and controlled offshore for UK tax purposes. In such a case, the UK tax treatment of any gains firstly depends on when the bond was effected. If the bond was already held in the ownership of the co...

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