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Overseas Trustees

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Trustees have an obligation to act in the best interests of their beneficiaries. This includes ensuring that they are up-to-date and compliant with the trust's UK tax obligations.

This is especially important with the advent of CCO, which requires that trustees have a demonstrable process in place to evidence that they are not facilitating tax evasion.

Hamilton Rose work closely with overseas trustees to ensure that they are operating in a UK tax efficient manner, that they are historically compliant and to ensure that any UK tax liabilities going forward are declared in full to HMRC.

We can take the historic and on-going tax compliance burden off your hands and provide invaluable independent support to any internal tax team.


Hamilton Rose have 30 years of combined experience advising trustees on their obligations under UK tax legislation if, for example, one of the beneficiaries becomes UK tax resident.

We regularly advise clients on establishing trust structures and work alongside trustees to ensure that they are maintained correctly.

This includes:

  • Reviews of the current structure,
  • Advice on how best to re-structure for optimal UK tax efficiency,
  • Detailed advice reports on the implications of certain transactions, and
  • The preparation and submission of, for example, IHT100 returns at Principal Charge or exit dates and on-going UK self-assessment income tax returns.

We are similarly well-equipped to advise on any underlying corporates, including reviews and opinions on tax residency, substance requirements and how best to structure the legal ownership of assets.

Hamilton Rose can ensure that a demonstrable process is in place for CCO purposes. We also work closely with a third party software provider that can enable trustees to automate this process as much as possible.

If a voluntary disclosures is required, we are highly experienced at undertaking the required financial analysis, ensuring that a full and complete disclosure is made and that any FTC penalties are mitigated as much as possible.

Overseas Trustees