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His Majesty's Revenue and Customs (commonly HM Revenue and Customs, or HMRC) [4] [5] is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, the administration of other regulatory regimes including the national minimum wage and the issuance of national insurance numbers.
The Investment Trust Companies (ITC), closed-end investment trusts that got investment management services from management companies, sued to recover overpaid VAT from the HMRC. The managers usually got paid by fees plus VAT. It was thought that there was no exemption possible, and VAT was charged at a standard rate.
A Discounted Gift Trust (DGT) is a type of UK trust arrangement usually set up in connection with an investment in either an onshore or offshore investment bond (insurance bond). It allows the gifting of a lump sum into a trust whilst retaining a lifelong 'income' from that money (technically withdrawals of capital), with the overarching aim of ...
The HMRC rules allow for a greater range of investments to be held than personal pension schemes, notably equities and property. Rules for contributions, benefit withdrawal etc. are the same as for other personal pension schemes. Another subset of this type of pension is the stakeholder pension scheme.
A QROPS should not incur an unauthorised payment nor scheme sanction charge and is deemed either a trust or a contract based offshore pension. As such the tax residence of the beneficial owner or beneficiaries is critical as some countries do not recognise trusts, the result being the prospect of taxation at source or upon receipt.
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The concept of an A&M trust emerged in England and Wales after the enactment of the Capital Taxes Act 1974 (CTA). The CTA discouraged the use of discretionary trusts by introducing new tax rules, but it made a specific exception for trusts designed to help young people under the age of 25.