Join Us - 15 & 16 April 2021

The IOMSCA & FCTCC present:
The Major Changes in Offshore Taxation
And How These Impact the Isle of Man

Location: Live Online Register
Event Overview

The Major Changes in Offshore Taxation
And How These Impact the Isle of Man

This conference is designed to bring delegates fully up to date with the major changes to the taxation provisions which apply to offshore structures in particular how they affect the IOM. Detailed notes will be provided and full account will be taken of the Budget and Finance Bill 2021 changes.

The new corporation tax rules which apply to IOM landlords holding UK will be covered and delegates will be provided with a check list on how to ensure golden trusts are not tainted (the unforgivable sin).

The new SDLT rules which apply to non-resident purchasers will be covered and the opportunities which IOM companies offer to UK based transactions.

The use of single premium policies will also be covered as they do have important strategic uses. Katherine Bullock will cover cases where UK property businesses should be rolled into an IOM company.

Conference Format:

Two ½ day sessions

Ticket Information:

£275 - ICAEW

£300 - non-ICAEW

Running Time:

Both Days -

2.00pm - 5.15pm


Live Online


6 Hours

Register Now*

* You will be redirected to the IOMSCA booking page.

Our Speakers

Expertise in depth

Patrick C Soares

Patrick C Soares

Head of Chambers     …genuinely fantastic; a walking encyclopaedia on tax

Patrick C Soares

Katherine Bullock

Katherine Bullock

Barrister     highly creative, always pragmatic

Katherine Bullock

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Reasons To Attend

Why You Should

A fantastic opportunity to hear top tax barristers discussing topical issues from the comfort of your own space

Event Schedule

When, What, Who

2:40 - 3:05 pm

Single Premium Offshore Policies

Their strategic roles in offshore settlements: What is happening in practice?

  • 5% per annum tax free
  • S720 defence
  • PPB and “influence”
  • Company above the bond but under a settlement
  • Case law
3:05 - 3:40 pm

The New Corporate Tax Regime which applies to IOM Landlords who own UK Invetsment Properties

  • Navigating the new normal – the essential guide for the IOM landlord
  • Choosing to remain outside the corporation tax regime
  • Future of the non-resident landlord scheme
  • Deductibility of finance costs
  • Loan relationships and CRS
  • Utilising losses and brought forward allowances
3:40 - 4:00 pm
4:00 - 4:30 pm

The UK / IOM Double Tax Treaty

Case studies on land transactions and interest payments

  • Fragmentation
  • The anti-avoidance clause and HMRC’s disclosure requirements
  • The trading/dividend route
  • Not all UK dividends paid to companies are tax free
  • Treaty overrides
  • Company above company structures
  • Interactions with the land transactions code
4.30 - 4:55 pm

Vital IHT Planning for Non-Doms

Use of IOM companies and settlememts

  • The FA 2020 excluded property trust changes
  • Additions – the new rules
  • Transfers between IOM settlements
  • Accumulating income
  • Unexpected 10 year and exit charges
  • How to spot a residential property interest
  • What we now know about Schedule A1
4:55 - 5:15 pm

Loans, Discount Bonds and Settlements

When they can be a disaster and when they are manna from heaven: Complete checklist

  • Comprehensive list of loan situations
  • Loans to settlor
  • S87 loans
  • S731 loans
  • Non-deductible loans on death
  • Golden trust loans
  • Loans to participators
  • Loans between settlements
  • Flip -flop loans
  • IHT and interest free loans
  • Loans and share transactions – s682
  • The FA 2020 Loan Charge
  • etc...
2:00 - 2:40 pm

The New SDLT Regime that applies to Non-Residents who purchase UK Property

  • The 2% increase
  • UK companies controlled by IOM companies caught
  • Rules for IOM settlements with UK beneficiaries
2:40 - 3:05 pm

The New Corporation Tax on Chargeable Gains Regime which applies to Non-UK Resident Companies

  • Taking advantage of the tax-free uplift
  • Restructuring pitfalls
  • Property rich companies
  • The critical exceptions to the charge and how to spot them
  • The essential checklist to navigate the new regime
3:05 - 3:40 pm

Non-Resident Companies Dealing in and Developing UK Land

  • When to use UK incorporated companies resident in the IOM
  • When to use IOM incorporated companies resident in the UK
3:40 - 4:00 pm

Coffee Break

4:00 - 4:30 pm

Vital 20 Point Checklist to ensure Golden Trusts created by Non-Doms in the IOM do not lose their Golden Status

  • Domicile statements
  • Catch-all clauses
  • Bounce-back deeds
  • Loans which are safe
  • Underlying company transfers
  • Sales and gifts
  • When a trust is not a settlement
  • etc...
4:30 - 4:55 pm

Rolling a UK Property Business into an IOM Company

  • Bucking the trend – why, when and how
  • Not all property businesses are the same: identifying the right property business
  • Over-riding deemed domicile
  • Why use an IOM company
4:55 - 5:15 pm

Transactions in Securities Code and Shares in IOM Companies - Changing Capital into Income

  • Loans which cannot be repaid
  • Liquidations
  • Settlements
  • Reporting obligations
  • Link with s720
5.15 - 5.15pm

Close of Conference - Day 2