Implied Trusts and Beneficial Ownership in Modern UK Tax Law

Implied Trusts and Beneficial Ownership in Modern UK Tax Law takes a look at that gap which lies between books on tax and those on trust law, and tries to bridge the two. How and why is beneficial ownership important in UK tax? How does HM Revenue & Customs and the law recognise the imposition of beneficial ownership for tax purposes via an implied trust? and when will UK tax law impose beneficial ownership on a different taxpayer from the legal owner of an asset or income source? As well as tracing the story behind Britain's ancient tax laws and courts, relevant legislation, cases and HM Revenue & Customs' guidance are all reviewed to paint a picture of how equity and implied trusts fit within today's tax laws. With the introduction of the 4th and 5th Anti-Money Laundering Directives, it is more important than ever to identify where beneficial ownership lies.

This book is ideal for academics and practitioners alike, looking at the history of equity law and the chancery court through a prism of taxation; as well as the practical application of beneficial ownership when considering a client's tax position. Those practitioners specialising in trusts should find this book an interesting and useful aid to supplement their knowledge of implied trusts and the relationship between the more-usual express trusts. Whether you are new to the tax profession, or a seasoned professional, there will be something here for everyone.