Overseas Chambers has elaborated a risk free method for onshore or offshore trustees to mitigate the effects of a beneficiary's move to France.

The proposed actions mitigate the exclusions frequently adopted in this area, by avoiding the effective expropriation.

The main text has been removed from public access;  so please ocntact Peter Harris for further advice and information.

The trustee is relieved of the declaratory and compliance issues on the move, as there is no French situs asset to which the then excluded beneficiary is entitled in France. The individual concerned has a specific "non asset" for French tax purposes which is legally non declarable for Wealth Tax purposes and is not within their legal or fiscal succession or "patrimoine" in France. Overseas Chambers stresses that this is a perfectly legitimate planning tool in France.

It also may provide a partial solution for those moving to France with SIPPS or stakeholder pensions and wishing to take a "rente" alongside.

Given the "enjeu", there will be a non-disclosure and confidentiality agreement required, with the payment on account for the advice, and Peter retains full intellectual property over this solution under the Bar Terms and conditions.

It will not work in all circumstances, but is ideal for an offshore trustee with a UK non domiciled beneficiary seeking to move to France for a fixed period or even permanently.

Please contact Peter Harris.