Offshore trusts: capital payments to UK beneficiaries free of gains under flip-flop II (Upper Tribunal) | Practical Law
Transfers made from a UK trust to UK beneficiaries as part of a flip-flop scheme were not subject to tax on the capital gains stockpiled in an offshore trust from which the funds had originated, the Upper Tribunal has held. (Bowring v HMRC [2015] UKUT 0550 (TCC)).