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Legal Briefing
HMRC's information powers and what they mean for offshore trustees
Practice Area: Succession Planning and Trusts
Sector: Business services
Jurisdiction: Channel Islands-Guernsey
Published: 20 July 2011
Law Firm: Mourant Ozannes
Overview
This briefing considers the recent First Tier Tax Tribunal case of Revenue and Customs v Panos Parissis and Adrian Towland and Ian Harrison and its practical implications for offshore trustees.
The case considered the question of whether or not documents in the possession of the professional trustee of three Guernsey trusts were in the 'power and possession' of the taxpayers for the purposes of section 20 of the UK Taxes Management Act 1970.
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