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Overseas Trusts


The UK’s anti-avoidance legislation is a minefield to navigate and trustees need to ensure that not only do they receive the correct advice on creation but that the entity regularly undertakes a “MOT” to ensure that there are no future issues building up.

Hamilton Rose are able to provide this specialist advice on creation and have significant experience ensuring that trustees are protected. As tax investigation specialists, we also have the knowledge and experience of understanding how HMRC may seek to enquire into such structures and can therefore put in place a pre-emptive rebuttal to ensure that enquiry costs are minimalised.

In this ever-increasing world of demonstrable risk compliance, it is vital that a trustee has tax audit on their file at regular intervals. This not only helps with demonstrating in the future that due care and attention has been taken at all times but also a significant tick in demonstrating a process for CCO purposes.


Hamilton Rose are working with a software provider that allows an online risk review to be undertaken by the trust service provider (TSP).

This review, completed by the TSP so there is no third party looking at your files, details the structure's exposure to UK tax risk and highlights where actions need to be taken or have already been taken. The review provides the TSP with a detailed report on the structure, allowing them to demonstrate the internal controls that they have, monitor their risk exposure and ensure their structures are compliant with UK tax on an on-going basis. Finally, the software is very useful if a TSP is on-boarding a book of clients as it gives a structure-by-structure oversight of the level of UK tax risk exposure that will be acquired.

If a more in-depth review is required then Hamilton Rose are ideally placed to assist, having the experience of hundreds of trust reviews.

Please contact us if this may be the solution you are looking for.