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Following the 1987 legislation new schemes were conceived whereby offshore trusts would be set up with foreign trustees, who would then form partnerships, as opposed to UK resident trustees. UK residents would then be beneficiaries of this trust without being members of the partnership.
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.
[1] [2] Donors to the Cup Trust benefited from tax deductions of up to £55 million. The Cup Trust has requested £46 million in Gift Aid from HM Revenue, arising from the donations which the trust has received. [1] [2] Gift Aid is a facility offered by HMRC for charities to reclaim basic rate tax on donations.
United Kingdom partnership law concerns the way that partnerships are formed or governed within the United Kingdom. Depending upon where the partnership was formed, English law , Scots law or Northern Irish law may apply in addition to statutes that create a framework across the UK.
Schemes are trust-based and established individually, usually by directors of limited companies [1] for specified employees of the company. Since Pension Simplification (also known as A-Day), SSAS has been available for establishment by those who are not in a limited company (i.e. Partnerships and Families). [2]
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.