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Since 6 April 2025 the offshore settlor-interested trust is transparent for income tax and capital gains tax, and its non-UK assets sit inside UK inheritance tax while the settlor is a long-term UK resident. The question left is whether to keep, collapse, or re-home it.
The offshore trust at the centre of most corridor families was built for a single job. A non-domiciled settlor, resident in the UK but taxed on the remittance basis, placed foreign assets into a non-resident settlement before becoming deemed domiciled. The trust held the assets outside the UK, the income and gains rolled up untaxed while they stayed offshore, and the foreign property sat outside UK inheritance tax because the settlor was not domiciled in the UK. The structure was not aggressive. It was the standard architecture that every adviser recommended and every private bank administered, and for the cohort it served it worked exactly as designed for two decades.
That job no longer exists. The Finance Act 2025 did not outlaw the offshore trust, and the trust deed signed years ago is still a valid settlement holding valid assets. What the Act removed was the tax result the trust was built to produce. From 6 April 2025 the protected-settlement regime is repealed, the remittance basis is gone, and inheritance tax depends on residence rather than domicile. The vehicle survived intact. The protection it carried did not. The trust that was a shield is now, for a UK-resident settlor, a standing cost: transparent for income tax and capital gains tax, and inside the inheritance tax net for as long as the settlor remains a long-term UK resident.
This is the position the relocation and restructuring market consistently states by half. The common formulation on adviser calls is that the trust is now transparent, meaning the settlor pays income tax and capital gains tax on the trust's foreign income and gains as they arise. That is true, and it is the half that the law piece on the repeal of the protected-settlement regime sets out in full. It is not the whole exposure. The same trust is also now within the inheritance tax relevant property regime, and a settlor-interested trust is within the gift-with-reservation rules on the settlor's death. The income and gains charge is annual and visible. The inheritance tax charge is periodic, larger, and routinely missed, because it does not appear on a tax return until a ten-year anniversary or a death forces it into view.
This article does not re-derive the repeal. It takes the repeal as the starting point and addresses the question the repeal creates: given that the trust is now transparent and exposed, what should be done with it. It sets out the three exposures the trust now carries, the inheritance tax engine that makes the structure expensive to hold and expensive to unwind, the Temporary Repatriation Facility window that cleans up the historic income before it closes, and the three forward options, keep, collapse, or re-home, with the cost mechanics of each. The decision is not whether the trust still works for tax. It does not. The decision is which exit, or which continuation, costs the family least over the next decade.
Before any decision can be made, the exposure has to be stated in full, because the structure is now caught by three separate parts of the tax code at once, and a plan that addresses one and ignores the others is not a plan.
Exposure one: income tax on the arising basis. The settlements code in section 624 of the Income Tax (Trading and Other Income) Act 2005 taxes the income of a settlor-interested settlement on the settlor as it arises. Between 2017 and 2025 that charge was blocked for non-domiciled settlors by the protected-foreign-source-income rules. The block is gone. A UK-resident settlor of an offshore settlor-interested trust is now taxed on the trust's foreign income as it arises within the trust, whether or not a penny is distributed, at income tax rates of up to 45%. Where the settlor is not within the settlements code, the Transfer of Assets Abroad rules in section 720 of the Income Tax Act 2007 reach the same income in the transferor-settlor's hands, again on the arising basis now that the remittance shelter has been removed.
Exposure two: capital gains tax on the arising basis. Section 86 of the Taxation of Chargeable Gains Act 1992 attributes the gains of a non-resident settlor-interested trust to the UK-resident settlor and taxes them as the settlor's own. The pre-2025 carve-out that blocked this attribution for non-domiciled settlors was removed by the Finance Act 2025. The trust can no longer roll up gains free of UK tax while the settlor is UK resident. Every disposal inside the trust is, in substance, a disposal taxed on the settlor in the year it happens. Capital payments and benefits paid out to UK-resident beneficiaries are separately matched to the trust's gains pool under section 87 TCGA 1992 and to its available relevant income under section 731 ITA 2007.
Exposure three: inheritance tax through the relevant property regime. This is the exposure the income-and-gains framing leaves out, and it is the larger of the three. Foreign property in a settlement is excluded property, and so outside UK inheritance tax, only while the settlor is not a long-term UK resident. Once the settlor crosses into long-term resident status, the trust's non-UK assets are relevant property, subject to a ten-year anniversary charge and to exit charges when property leaves the trust. The trust is no longer a way to hold wealth outside the inheritance tax net. While the settlor is a long-term resident, it is wealth held inside the net, charged on a ten-year cycle that runs whether or not anyone is paying attention.
The three exposures share a single switch, and that switch is the settlor's UK tax status. While the settlor is UK resident, the income and gains are attributed. While the settlor is a long-term UK resident, the inheritance tax regime applies to the trust assets. The settlor's residence position is therefore not one factor among several. It is the master control for the entire structure, which is why two of the three forward options turn on moving it.
The inheritance tax exposure is the part of the analysis that the standard transparency briefing omits, and it is where the real cost of holding the trust accrues. The mechanics are worth setting out in full, because they drive both the cost of keeping the trust and the cost of collapsing it.
The excluded property test now turns on the settlor, tested afresh each time. Under section 48 of the Inheritance Tax Act 1984 as rewritten by the Finance Act 2025, non-UK property in a settlement is excluded property only if the settlor is not a long-term UK resident at the time of the relevant charge. HMRC's manual is direct on the point: when a settlor is a long-term UK resident, any assets they have settled, even if settled at a time when the settlor was not UK resident or was domiciled outside the UK, are not excluded property. The status of the trust is no longer fixed at the date it was created by reference to the settlor's domicile then. It is tested again at every chargeable event in the trust's life: each ten-year anniversary, each exit, and the settlor's death. A long-standing trust settled decades ago by a settlor who is now a long-term UK resident holds relevant property today, regardless of how clean its origin was.
The ten-year anniversary charge. Where the trust holds relevant property, it pays a periodic charge on each ten-year anniversary of its creation. The maximum effective rate is 6% of the value of the relevant property above the available nil-rate band. Six per cent of a trust holding tens of millions is a significant sum falling due on a date set by the trust deed, not by the family's planning. The charge is the price of holding the assets inside a settlement whose settlor is a long-term UK resident, and it recurs every decade for as long as that status holds.
The exit charge. When property leaves the trust between anniversaries, whether by distribution to a beneficiary or on a winding-up, an exit charge applies, calculated by reference to the rate at the last anniversary and the number of complete quarters since then. The exit charge is what makes collapsing the trust a taxable event in its own right, separate from the income and gains matching that a distribution also triggers. A trust cannot simply be emptied without cost once it holds relevant property.
Transitional rate relief softens, but does not remove, the first charges. The Finance Act 2025 provides transitional relief for trusts whose non-UK property was excluded property immediately before 6 April 2025 but is relevant property afterwards because the settlor is a long-term resident. In broad terms the relief reduces the rate of the charge to reflect that the property was outside the regime before 6 April 2025, so the first ten-year anniversary charge after the change is not levied on the full pre-2025 period. The relief reduces the early charges; it does not take the trust out of the relevant property regime, and it runs out as the post-2025 period lengthens. It buys time. It does not solve the exposure.
The gift-with-reservation overlay. A settlor-interested trust carries a second inheritance tax exposure on top of the relevant property charges. Because the settlor can benefit from the trust, the gift into it is a gift with reservation of benefit under section 102 of the Finance Act 1986, and the trust's property is treated as remaining part of the settlor's estate. HMRC's manual confirms that where the settlor is a long-term UK resident at death, the foreign property in the settlement is brought into charge on death through the reservation; only where the settlor is not a long-term resident at death is that property excluded. There is double-charge relief, but it is narrow: the relief operates against the charge on the settlor as an individual, and it does not reduce the trust's own ten-year anniversary or exit charges. The settlor-interested trust is therefore exposed to inheritance tax on two tracks at once, the relevant property track on the trust and the reservation track on the death estate, with relief only on the overlap.
Adding to the trust now triggers an entry charge. A settlor who is a long-term UK resident and adds assets to the trust makes a chargeable transfer into relevant property, which attracts an immediate inheritance tax entry charge of 20% on the value added above the nil-rate band. The instinct to top up an existing structure, common when a settlor wants to consolidate wealth, is now a 20% event. The trust that was a place to accumulate is now a place that taxes accumulation.
The full interaction of these charges with the long-term resident test for the individual is set out in the analysis of the long-term resident inheritance tax tail. The point for the restructuring decision is that the inheritance tax engine runs on the settlor's status and the trust's anniversary calendar, and both of those are things a plan can influence. The income and gains charge is a running cost. The inheritance tax charges are the structural cost, and they are what make the keep-or-collapse decision a question of arithmetic rather than instinct.
Before deciding the trust's future, there is a piece of the past to clean up, and it is on a clock that closes before most of the other decisions have to be made.
The income that accumulated inside the trust under the old rules did not disappear when the protections were repealed. Foreign income that arose to the trust between 6 April 2017 and 5 April 2025 and qualified as protected foreign-source income, and the earlier transitional trust income, now sits as a stockpiled pool attached to the settlement. The pool is not taxed while it sits there. It becomes taxable when a benefit is paid out after 5 April 2025 to a UK-resident settlor or close family member and is matched against the stockpile under section 643A ITTOIA 2005, taxing the recipient at current rates on income that was protected when it arose. The historic income is a latent charge waiting for the first distribution to release it.
The Temporary Repatriation Facility is the tool that prices that latent charge down, and it has a hard expiry. A former remittance-basis user can designate qualifying pre-6 April 2025 foreign income and gains, and certain trust distributions and benefits to the extent they would have been taxable on remittance, at a reduced rate: 12% in 2025/26, 12% in 2026/27, and 15% in 2027/28. After 5 April 2028 the facility closes and is not replaced. The mechanics, the eligibility, and the scope of qualifying overseas capital are set out in the analysis of the Temporary Repatriation Facility. Two points matter for the trust decision specifically.
The designation has to be run at trustee and beneficiary level together. A capital payment or benefit from the trust interacts with the trust's own matching records under sections 87 TCGA 1992 and 731 ITA 2007, and the amount that can be cleansed depends on what the trustees distribute and how it matches. An adviser who designates at the individual level without engaging the trustees, or trustees who distribute without engaging the settlor's designation, will leave value on the table and create tracing problems for later distributions. The facility rewards a single integrated analysis across both levels.
The TRF window and the restructuring decision are not the same decision, but they share a deadline. Cleaning up the historic stockpile through the facility makes sense for many trusts regardless of whether the structure is eventually kept, collapsed, or re-homed, because it converts a contingent 45% charge on future distributions into a fixed 12% or 15% cost now. But it has to be done by 5 April 2028, which is sooner than the trust's next anniversary for many settlements and sooner than the end of most settlors' inheritance tax tails. The historic clean-up is the first action, and it runs ahead of the structural decision rather than waiting for it.
With the exposures stated and the historic income addressed, the forward decision reduces to three options. They are not mutually exclusive over time, and the right answer for many families is a sequence rather than a single choice, but each has a distinct cost profile and each suits a distinct purpose.
Keep and strip. The trust stays in place and the trustees manage it to minimise the annual exposure. Income is directed where possible into forms that reduce the arising-basis charge, investment selection favours capital growth over distributed yield, and distributions to UK-resident beneficiaries are avoided or timed against the stockpile matching rules. The settlor pays the income tax and capital gains tax attributed each year, and the trust pays the ten-year anniversary charge of up to 6% when it falls due. This is the most expensive option as a running cost, because the arising-basis tax and the periodic charge are both paid for as long as the structure and the settlor's status persist. It is the cheapest option as a one-off, because nothing is unwound and no exit charge or matching event is triggered. It suits a trust with a genuine non-tax purpose, succession across a dispersed family, asset protection, governance of a family business, where the structure earns its cost in something other than tax, and a settlor with no near-term intention to leave the UK.
Collapse to the individuals. The trust is wound up and its assets are distributed to the beneficiaries or back to the settlor. The attraction is finality: once the assets are in individual hands, the annual attribution stops, the anniversary charges stop, and the compliance burden ends. The cost is that the winding-up is itself a cluster of taxable events. The distribution is matched against the trust's gains pool under section 87 and against the stockpiled income under section 643A, producing income tax and capital gains tax charges in the year of collapse. The exit from the relevant property regime triggers an inheritance tax exit charge on the relevant property leaving the trust. A trust holding substantial assets and a large stockpile can generate a significant single-year tax bill on collapse, and that bill has to be funded. Collapse suits a trust whose original purpose has lapsed, where the stockpile is small enough that single-year matching is tolerable, and where the family has the liquidity to pay the charges and wants the structure gone.
Re-home the structure. The third option keeps the wealth in a structure but changes the structure or the settlor's position so that the exposure falls away. It takes three forms, and the choice among them is the substance of the corridor decision.
The first form is to migrate the settlor. Because the income, gains, and inheritance tax exposures all switch on the settlor's UK tax status, a settlor who ceases to be UK resident under the Statutory Residence Test stops being subject to the arising-basis attribution from the date of departure, and once the settlor is past the long-term resident inheritance tax tail, the trust's non-UK property becomes excluded property again and leaves the relevant property regime. The day-count discipline that governs the departure is the Statutory Residence Test, and the inheritance tax tail that has to run before the trust is fully clear is the subject of the long-term resident IHT tail analysis. Migrating the settlor does not require touching the trust at all; it changes the master control directly. It suits a family whose corridor destination is independently attractive and whose mobility genuinely supports a departure, which for the corridor cohort frequently means the UAE.
The second form is to move the assets into a corporate holding structure that achieves the family's commercial aims without the settlor-interested trust's tax profile. A UK holding company, analysed in the guide to the UK holding company and the substantial shareholding exemption, can hold and consolidate operating businesses and investments with a known corporation tax treatment, which for some families is preferable to the unpredictable arising-basis attribution of a transparent trust. An Irish holding company, set out in the Ireland holding company in the UK-UAE corridor analysis, offers an EU-resident corporate platform with its own participation exemption and treaty network. Neither is a trust substitute for succession purposes, but for the asset-holding and business-consolidation purposes that many trusts were quietly serving, a holding company can carry the function without the transparency charge.
The third form is to move the wealth into a vehicle built for succession that is not a settlor-interested trust. A foundation established in the DIFC or ADGM is an orphan legal person rather than a settlement, and it is the contemporary route for families who want the governance and succession function of a trust without holding a structure that is transparent to its settlor. The foundation carries its own UK tax characterisation questions that have to be resolved before it is used, because a foundation that HMRC treats as a settlement can reproduce the very exposure the family is trying to escape. That analysis is a separate exercise and is addressed in its own right; for the purpose of this decision, the foundation is the succession-focused re-homing option, distinct from the corporate holding company and from the settlor's own migration.
No single option is correct in the abstract. A trust with a real succession purpose and a settlor staying in the UK is kept and stripped. A trust whose purpose has lapsed and whose stockpile is small is collapsed. A trust holding a family business for a settlor who is leaving anyway is left in place while the settlor migrates and the tail runs. The options also combine: keep and strip for two years while the settlor's exit is prepared, migrate the settlor, and collapse or re-home the residue once the trust is outside the regime. The skill is not in choosing one label. It is in sequencing the actions against the three clocks that govern the cost.
Five patterns produce most of the expensive mistakes as families confront the transparent trust. None is a failure of arithmetic. Each is a failure to read the structure as a live decision rather than a settled arrangement.
Trap one: set and forget. The most common and most costly error predates 6 April 2025. A trust established for a non-domiciled settlor a decade or more ago was administered on autopilot, on the assumption that the protections were permanent and the structure needed no review. The protections were repealed with a long lead time, and a trust that was not reviewed before April 2025 has been running as a transparent, exposed structure since, accruing arising-basis charges and moving towards a relevant property anniversary that the family has not modelled. The architectural answer is to treat every pre-2025 offshore settlor-interested trust as requiring a full review now, because the structure is already in the new regime whether or not anyone has looked at it.
Trap two: assuming excluded property status survived. Advisers and families frequently believe that because the trust was excluded property when it was settled, it stays excluded property for life. That was the old law, where the trust's status was fixed at creation by the settlor's domicile. Under the rewritten section 48 IHTA 1984 the test is applied afresh at each chargeable event by reference to the settlor's long-term resident status at that time. A trust that was excluded property at creation is relevant property now if the settlor is a long-term UK resident, and its assets are exposed to the anniversary and exit charges. The architectural answer is to test the trust's status against the settlor's current residence position, not against its origin.
Trap three: ignoring the inheritance tax charge because no distributions are made. A family that takes no distributions from the trust often concludes there is no inheritance tax problem, because nothing is leaving the structure. The relevant property charges do not depend on distributions. The ten-year anniversary charge falls on the value held in the trust on the anniversary date whether or not anything has been paid out, and the gift-with-reservation charge falls on the settlor's death regardless of distribution history. A dormant trust is not a safe trust; it is a trust accruing a periodic charge silently. The architectural answer is to diarise the trust's anniversary and model the charge ahead of it, not to treat inactivity as protection.
Trap four: collapsing the trust without modelling the exit and matching charges. A family that decides the trust is now pointless sometimes moves to wind it up quickly, treating the collapse as a simple distribution. The winding-up triggers an inheritance tax exit charge on the relevant property leaving the trust, capital gains matching under section 87, and income matching against the stockpile under section 643A, all in the year of collapse and all requiring funding. A collapse executed without modelling these charges can produce a tax bill larger than several years of simply keeping the trust. The architectural answer is to model the full cost of collapse against the running cost of keeping before pulling the structure apart, because collapse is sometimes the more expensive option.
Trap five: missing the TRF window for the historic stockpile. The Temporary Repatriation Facility closes on 5 April 2028, and it is the only route to cleanse the trust's stockpiled pre-2025 income at 12% or 15% rather than facing matching at up to 45% on future distributions. A family that defers the structural decision often defers the TRF analysis with it, and lets the window close, leaving the historic stockpile to be taxed at full rates whenever the first post-window distribution is matched against it. The historic clean-up is on a shorter clock than the structural decision and has to be handled first. The architectural answer is to run the TRF designation before 5 April 2028 as a standalone action, independent of whether the trust is eventually kept, collapsed, or re-homed.
The common thread is that the trust is being treated as a fixed object when it has become a decision with a timetable. The exposures accrue whether or not the family engages, the cheapest historic clean-up has the nearest deadline, and the structural choice carries costs that have to be modelled rather than assumed.
The transparent trust does not sit in isolation. It connects to the rest of the corridor at the points where the settlor's status, the historic income, and the destination structure are decided, and the restructuring is the act of sequencing three clocks that run on different calendars.
The settlor's residence position is the master control. Both the income-and-gains transparency and the inheritance tax exposure switch on the settlor's UK tax status, decided by the Statutory Residence Test. A settlor who migrates stops the arising-basis attribution from the date of departure, but the inheritance tax exposure persists through the long-term resident tail. The migration is not complete for trust purposes until the settlor is past that tail.
The inheritance tax tail runs for up to ten years after departure. The long-term resident IHT tail keeps the settlor's worldwide estate, and the trust's relevant property status, inside UK inheritance tax for between three and ten tax years after the settlor leaves. The trust's non-UK property does not become excluded property again until the settlor is past the tail, so the anniversary charges can continue to fall during the years after departure. Aligning the trust's anniversary calendar with the end of the settlor's tail is the difference between a clean exit and an avoidable charge.
The TRF window closes first, on 5 April 2028. The historic stockpile clean-up has the nearest deadline of the three clocks, sooner than most settlors' tails and sooner than many trusts' next anniversary. The Temporary Repatriation Facility is handled first precisely because it expires first, regardless of where the structural decision lands.
The destination structure has to be chosen before the assets move. If the answer is to re-home the wealth, the receiving structure, a UK holding company, an Irish holding company, or a UAE foundation, has to be analysed and stood up before the trust is unwound, so that the exit from the trust and the entry into the new vehicle are coordinated rather than sequential. A collapse with no destination is just a taxable distribution; a re-homing is a planned migration of the assets into a structure chosen for the purpose the trust used to serve.
The wider corridor exit ties the trust decision to the family's move. For many corridor families the trust decision is one workstream inside a larger relocation to the UAE, and it interacts with the inheritance tax tail, the pension position, and the pre-2025 income clean-up that the non-dom abolition and the UAE inheritance tax tail analysis brings together. The trust is rarely restructured in isolation; it is restructured as part of the family's exit, and the sequencing of the trust clocks has to fit the sequencing of the move.
The theme is that the trust has become a timing problem rather than a structuring problem. The structure itself is understood. What decides the cost is the order in which the historic income is cleansed, the settlor's status is changed, the trust's anniversary is met or avoided, and the assets are moved to their destination. The families that pay the most are not the ones with the wrong structure. They are the ones who sequence the clocks in the wrong order, or do not sequence them at all.
For a UK-resident settlor, no, not in the way it was. The Finance Act 2025 repealed the protected-settlement rules, so the trust's foreign income and gains are now taxed on the settlor on the arising basis under section 624 ITTOIA 2005 and section 86 TCGA 1992, and the trust's non-UK assets are within UK inheritance tax through the relevant property regime while the settlor is a long-term UK resident. The trust remains a valid legal structure and can still serve genuine succession, governance, and asset-protection purposes, but the tax shield it was built to provide has gone.
It means the trust is looked through for income tax and capital gains tax, so the settlor is taxed on the trust's income and gains as if they were the settlor's own, as they arise, whether or not they are distributed. Before 6 April 2025 this transparency was switched off for non-domiciled settlors by the protected-foreign-source-income rules. From 6 April 2025 those rules are repealed, and the transparency applies in full to UK-resident settlors of settlor-interested offshore trusts.
While you are a long-term UK resident, yes. Under section 48 IHTA 1984 as amended, the non-UK property in your settlement is excluded property only if you, as settlor, are not a long-term UK resident at the time of the charge. Once you have been UK resident for 10 of the previous 20 tax years, the trust's foreign assets are relevant property, subject to a ten-year anniversary charge of up to 6% and to exit charges. A settlor-interested trust is also within the gift-with-reservation rules, so its assets can be charged on your death as well.
It is one of three options, and it is not automatically the cheapest. Winding up the trust triggers an inheritance tax exit charge on the relevant property, capital gains matching under section 87 TCGA 1992, and income matching against the stockpiled pre-2025 income under section 643A ITTOIA 2005, all in the year of collapse. For a trust with substantial assets and a large stockpile, that single-year bill can exceed several years of simply keeping the trust. The collapse cost has to be modelled against the running cost before deciding.
Through the Temporary Repatriation Facility, before it closes. Pre-6 April 2025 income and gains, and certain trust distributions and benefits, can be designated at 12% in 2025/26 and 2026/27, or 15% in 2027/28, after which the amount is cleansed. The window closes on 5 April 2028, and the designation has to be coordinated between the settlor and the trustees, because the amount that can be cleansed depends on how trust distributions match against the trust's own records.
It does, but not immediately. The income and capital gains attribution stops when you cease to be UK resident under the Statutory Residence Test. The inheritance tax exposure persists through the long-term resident tail, which runs for between three and ten tax years after you leave depending on how long you were resident. The trust's non-UK property becomes excluded property again only once you are past that tail, so anniversary charges can still fall during the years immediately after departure.
The function the trust served can be carried by a different structure. For asset-holding and business consolidation, a UK holding company or an Irish holding company provides a corporate platform with a known tax treatment. For succession and governance specifically, a DIFC or ADGM foundation is an orphan legal person used as the contemporary alternative to a settlor-interested trust, subject to resolving how it is characterised for UK tax before it is used. The right replacement depends on whether the purpose is holding assets, running a business, or passing wealth between generations.
The settlor-transparency and the gift-with-reservation charge apply to the settlor, not to a beneficiary who did not settle the trust. A UK-resident beneficiary who is not the settlor is instead taxed on capital payments matched under section 87 TCGA 1992 and on benefits matched against available relevant income under section 731 ITA 2007, on an arising basis now that the remittance basis has been removed. The inheritance tax relevant property charges still apply to the trust by reference to the settlor's status, not the beneficiary's.
The offshore trust was the right answer to a question the UK stopped asking on 6 April 2025. The deed is still valid, the trustees are still in office, and the assets are still there. What has gone is the reason the structure was built, and in its place is a transparent, charged vehicle that costs the family money every year it is held without a decision. Keeping it, collapsing it, and re-homing it are all defensible. Leaving it untouched is the one option that is not...
A DIFC or ADGM foundation is an orphan legal person, neither a company nor a trust, and the structure families reach for once the offshore trust became settlor-transparent in 2025. For a UK-resident founder it does not escape the settlements code or inheritance tax by itself.
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