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<p>UK residents are taxable on their worldwide income wherever it arises—including situations where it arises by way of foreign partnerships. Section 58 of Finance Act 2008 was enacted to help put that beyond doubt and in so doing, made clear that a wholly artificial tax avoidance scheme involving a foreign partnership comprised of foreign trustees did not work. As section 58 retrospectively clarified existing legislation, its introduction had no affect on any taxpayers tax position. HMRC has currently identified around 2,000 individuals who used the avoidance scheme or one of its variants and whose tax returns are currently under inquiry.</p> |