Pierre Dubois, a French citizen and resident, owns valuable works of art
situated in several galleries and museums in the UK. The value of these works of
art would certainly exceed the inheritance tax threshold for UK inheritance tax
purposes, if Pierre would die in the very near future.
Pierre wonders how he can avoid exposure to UK inheritance tax.
If Pierre would die whilst owning these works of art in the UK, then UK
inheritance tax liability will certainly arise. One way to avoid this is to
create an offshore trust, for example in the Isle of Man. The offshore trustees
can then establish an offshore company to take ownership of the works of art. If
this two-tier structure is established, then the works of art concerned can be
brought into and enjoyed in the UK without any exposure to UK inheritance tax as
the trust property will consist of the shares in the offshore company. For UK
tax purposes, these shares are exempt property, as they are situated outside the
A bespoke 'offshore' solution can be complex and requires careful planning and execution. We therefore encourage our clients to contact us directly, without obligation.
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