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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.
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All assets are permitted by HMRC, however some will be subject to tax charges. The assets that are not subject to a tax charge are: [5] Stocks and shares listed on a recognised exchange; Futures and options traded on a recognised futures exchange; Authorised UK unit trusts and open-ended investment companies and other UCITS funds
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.
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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.