Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Company definition

What does Company mean? In legal practice, company describes an incorporated association formed to carry on business or another lawful purpose. Across England and Wales, Scotland and Northern Ireland this ordinarily means a body corporate formed and registered under the Companies Act 2006; in Ireland, under the Companies Act 2014. A company has separate legal personality (Salomon v A Salomon & Co Ltd), can own assets, enter contracts, sue and be sued, and typically provides limited liability for its members. Common forms are the private company limited by shares (Ltd), the public limited company (plc), the company limited by guarantee and the unlimited company....

UK tax of underlying companies in offshore trusts: attribution rules, IHT (including UK residential property), ATED, double taxation, and FA 2025 non-dom and residence-based IHT changes

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Practice notes

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

The Finance Act 2025 (FA 2025), which secured Royal Assent on 20 March 2025, enacts the removal of the remittance basis and introduces a residence-based system from 6 April 2025. It also makes residence, rather than domicile, the determinant for inheritance tax exposure.

Revises the rules for excluded property status
Removes protected settlements status for offshore trusts
Updates overseas workday relief

For further details, refer to Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

This Practice Note briefly sets out the pros and cons of trustees using a Company to hold Investment assets instead of holding them directly, and considers both UK resident and domiciled individuals and UK resident, non-domiciled individuals.

Non-tax reasons for using a Holding company

Although trusts may own assets outright, trustees commonly incorporate an underlying holding company to own such assets...

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Web page updated on 21/05/2026

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