The ten-year tax charge that HMRC levy on almost all trusts can be a minefield for many businesses involved in the offshore trust/fiduciary world. It places responsibilities on businesses which, if not dealt with properly, can be problematic for trustees and clients alike.


It will guide participants through the rules and how they apply. Some of those applications may come as a surprise to some. It will be both knowledge enhancing, but also practical with in-class exercises and interactivity, including completion of a Return itself.


The course is delivered by Bernard O’Kelly BCL, AITI CTA, Barrister-at-Law, Fios Limited, Isle of Man. Bernard has been providing practical tax advice and solutions ‘offshore’ for 30 years.


Who should attend?

  • Accountants
  • Bankers
  • CSPs
  • Custodians
  • Fiduciary specialists
  • Tax specialists
  • Trustees


Content Overview

To whom does it apply? When is it relevant?

UK domicile and UK deemed domicile


When does the Charge apply?

Residential Property Interest

  • Definition and applications (or not)
  • Loans
  • Non-UK situs assets
  • The Two-Year Tail


The Return and Payment

  • Who has responsibility?
  • Penalties on late returns and the HMRC scope
  • Payments
  • Late payments and penal rates of interest
  • Paying by instalments



1 day (over 2 x half days)



£420 + VAT


A 10% discount will be applied to the 3rd or subsequent attendees from the same firm.

Companies may wish to consider the delivery of an in-house workshop.


Contact: Gerry Ganly

Email, call +44 (0)7624 490809 


Gerry Ganly head shot

Gerry Ganly

Gerry Ganly is an experienced industry practitioner, with skills and knowledge across the financial sectors. He has held senior roles in compliance, cash management and treasury, and relationship management. He has worked in, and consulted with, banks, compliance, CSP and investment environments