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Foreign structures are often difficult to understand from a UK tax point of view. In order for them to be recognised it is necessary for them to be categorised as a trust, a company or a partnership.

Where it is necessary for a foreign structure to be analysed for the purposes of UK taxation, the structure will be considered in relation to the rules of the foreign territory in which it is governed. However it will then be necessary for UK tax law to be applied.

There are a number of different foreign structures that a practitioner may come across. Care should be taken in relation to them and cautious analysis made. Where appropriate, practitioners should also seek specialist advice.

Specific examples are considered below to give an illustration of the complexities that can arise in relation to the recognition of foreign structures.

Although domicile is removed as the connecting factor for IHT from 6 April 2025 it remains as a common law concept and its relevance for determining issues concerning