Accurate tracking and reporting for UK tax exposure on accumulated income and gains

Trusts and foundations with UK-resident beneficiaries must carefully monitor and calculate deemed income pools and stockpiled gains to comply with UK tax rules on distributions. These calculations help determine whether distributions from offshore structures are taxable to UK beneficiaries and, if so, how much is subject to income tax or capital gains tax under anti-avoidance legislation such as the transfer of assets abroad (TOAA) rules or the stockpiled gains regime under TCGA 1992.

Our Expertise

At BCR, our team of experts specialise in preparing and maintaining detailed income pool and gain accumulation records for offshore trusts and foundations. Our reports provide trustees, beneficiaries, and advisers with clarity and defensible documentation to support UK tax filings.

Our Approach

Failure to track and correctly report deemed income and accumulated gains can lead to significant UK tax liabilities for beneficiaries, including exposure to tax at higher rates (up to 45 percent), interest, and penalties. Proper documentation also supports HMRC disclosures, protects trustees from allegations of negligence, and enables beneficiaries to plan effectively.

We support the following clients:

• Trustees of non-UK trusts and foundations with UK-resident beneficiaries.
• Legal and tax advisers to high-net-worth UK families with offshore structures.
• Beneficiaries receiving distributions or benefits from Jersey and Guernsey vehicles.
• Family offices responsible for reporting under UK anti-avoidance rules.

Our calculations support with the following:

• UK income tax returns for beneficiaries.
• IHT risk management through proper trust classification.
• CRS/FATCA risk profiling.
• Litigation and family settlement contexts involving trust wealth.

Our services

We provide the support with the following:

• Establishing deemed income pools, including interest, dividends, and other taxable income retained in the trust
• Tracking stockpiled gains from disposal of assets not yet distributed
• Allocation of historic income and gains across tax years in accordance with UK rules
• Proportioning gains to beneficiaries based on distribution dates and values
• Supporting the remittance basis position of UK-resident non-domiciled beneficiaries
• Assisting beneficiaries and their advisers with disclosures to HMRC
• Producing schedules for annual trustee reviews or disclosure packs
• Coordinating with UK legal and tax advisers to ensure full alignment with beneficiary filings.

Our values in action

Excellence: Calculations are precise, HMRC-compliant, and supported by clear audit trails.
Delivery: Reports are delivered on time, aligned with trust reporting cycles and beneficiary needs.
Respect: We handle sensitive financial matters with care and discretion.
Elegance: Outputs are presented clearly, with logical schedules and plain language summaries where needed.‍

Why BCR Pro

Trustees and advisers of offshore trusts and foundations with UK-resident beneficiaries choose BCR Pro for specialist support in calculating and reporting deemed income and stockpiled gains, ensuring compliance with complex UK anti-avoidance tax rules.