October 13, 2026
What happens when a single mistake in tax advice puts millions of pounds at risk?
In a recent Jersey Royal Court judgment, Representation of B re the Puffin Trust [2026] JRC 233, a trust into which approximately £17.3 million had been transferred was declared invalid after incorrect UK tax advice resulted in substantial unexpected tax liabilities.
The case serves as a cautionary reminder of the importance of getting tax advice right from the outset, particularly when significant wealth and complex financial arrangements are involved.
In April 2018, a woman established a Jersey trust as part of her family's long-term tax and succession planning.
Before establishing the trust, she sought professional advice regarding her UK domicile status. She was advised that she would not become deemed domiciled in the UK until April 2020, allowing her to establish the trust before that date.
However, her adviser had overlooked an earlier period of UK residence. In reality, she had already become deemed UK-domiciled in April 2017.
The mistake was discovered in December 2025, exposing her to substantial unexpected tax liabilities, including an initial inheritance tax charge of approximately £4.245 million and interest of approximately £1.63 million.
The Royal Court accepted that the trust would not have been established had the correct advice been provided. It therefore declared the trust invalid and set aside the transfers made into it.
Although the decision addressed the inheritance tax consequences, certain income tax and capital gains tax liabilities remained.
Read the full Royal Court judgment: Representation of B re the Puffin Trust [2026]JRC 233.
This case highlights how even a seemingly small oversight can have substantial financial consequences.
For individuals with international connections, tax planning can be particularly complex. Residence history, domicile status and the interaction between different tax jurisdictions can all influence the effectiveness of a proposed arrangement.
As the Puffin Trust case demonstrates, failing to consider one important detail can result in millions of pounds in unexpected liabilities.
While the Royal Court was able to provide relief in this instance, such remedies are not guaranteed. Correcting mistakes after financial arrangements have been established can be complicated, costly and time-consuming.
Seeking specialist tax advice before making significant financial decisions can help identify potential risks, avoid unexpected liabilities and ensure that arrangements are appropriate for your circumstances.
At BCR Professional Services, we provide tailored tax advice to individuals, families and businesses, helping them navigate complex UK and Jersey tax considerations.
Whether you are considering establishing a trust, reviewing existing arrangements or planning for the future, our team can help you understand the potential tax implications and make informed decisions.
Getting the right advice from the outset can help protect your wealth and avoid costly mistakes further down the line.
Contact BCR Professional Services to discuss how we can help
What happens when a single mistake in tax advice puts millions of pounds at risk?
In a recent Jersey Royal Court judgment, Representation of B re the Puffin Trust [2026] JRC 233, a trust into which approximately £17.3 million had been transferred was declared invalid after incorrect UK tax advice resulted in substantial unexpected tax liabilities.
The case serves as a cautionary reminder of the importance of getting tax advice right from the outset, particularly when significant wealth and complex financial arrangements are involved.
In April 2018, a woman established a Jersey trust as part of her family's long-term tax and succession planning.
Before establishing the trust, she sought professional advice regarding her UK domicile status. She was advised that she would not become deemed domiciled in the UK until April 2020, allowing her to establish the trust before that date.
However, her adviser had overlooked an earlier period of UK residence. In reality, she had already become deemed UK-domiciled in April 2017.
The mistake was discovered in December 2025, exposing her to substantial unexpected tax liabilities, including an initial inheritance tax charge of approximately £4.245 million and interest of approximately £1.63 million.
The Royal Court accepted that the trust would not have been established had the correct advice been provided. It therefore declared the trust invalid and set aside the transfers made into it.
Although the decision addressed the inheritance tax consequences, certain income tax and capital gains tax liabilities remained.
Read the full Royal Court judgment: Representation of B re the Puffin Trust [2026]JRC 233.
This case highlights how even a seemingly small oversight can have substantial financial consequences.
For individuals with international connections, tax planning can be particularly complex. Residence history, domicile status and the interaction between different tax jurisdictions can all influence the effectiveness of a proposed arrangement.
As the Puffin Trust case demonstrates, failing to consider one important detail can result in millions of pounds in unexpected liabilities.
While the Royal Court was able to provide relief in this instance, such remedies are not guaranteed. Correcting mistakes after financial arrangements have been established can be complicated, costly and time-consuming.
Seeking specialist tax advice before making significant financial decisions can help identify potential risks, avoid unexpected liabilities and ensure that arrangements are appropriate for your circumstances.
At BCR Professional Services, we provide tailored tax advice to individuals, families and businesses, helping them navigate complex UK and Jersey tax considerations.
Whether you are considering establishing a trust, reviewing existing arrangements or planning for the future, our team can help you understand the potential tax implications and make informed decisions.
Getting the right advice from the outset can help protect your wealth and avoid costly mistakes further down the line.
Contact BCR Professional Services to discuss how we can help
What happens when a single mistake in tax advice puts millions of pounds at risk?
In a recent Jersey Royal Court judgment, Representation of B re the Puffin Trust [2026] JRC 233, a trust into which approximately £17.3 million had been transferred was declared invalid after incorrect UK tax advice resulted in substantial unexpected tax liabilities.
The case serves as a cautionary reminder of the importance of getting tax advice right from the outset, particularly when significant wealth and complex financial arrangements are involved.
In April 2018, a woman established a Jersey trust as part of her family's long-term tax and succession planning.
Before establishing the trust, she sought professional advice regarding her UK domicile status. She was advised that she would not become deemed domiciled in the UK until April 2020, allowing her to establish the trust before that date.
However, her adviser had overlooked an earlier period of UK residence. In reality, she had already become deemed UK-domiciled in April 2017.
The mistake was discovered in December 2025, exposing her to substantial unexpected tax liabilities, including an initial inheritance tax charge of approximately £4.245 million and interest of approximately £1.63 million.
The Royal Court accepted that the trust would not have been established had the correct advice been provided. It therefore declared the trust invalid and set aside the transfers made into it.
Although the decision addressed the inheritance tax consequences, certain income tax and capital gains tax liabilities remained.
Read the full Royal Court judgment: Representation of B re the Puffin Trust [2026]JRC 233.
This case highlights how even a seemingly small oversight can have substantial financial consequences.
For individuals with international connections, tax planning can be particularly complex. Residence history, domicile status and the interaction between different tax jurisdictions can all influence the effectiveness of a proposed arrangement.
As the Puffin Trust case demonstrates, failing to consider one important detail can result in millions of pounds in unexpected liabilities.
While the Royal Court was able to provide relief in this instance, such remedies are not guaranteed. Correcting mistakes after financial arrangements have been established can be complicated, costly and time-consuming.
Seeking specialist tax advice before making significant financial decisions can help identify potential risks, avoid unexpected liabilities and ensure that arrangements are appropriate for your circumstances.
At BCR Professional Services, we provide tailored tax advice to individuals, families and businesses, helping them navigate complex UK and Jersey tax considerations.
Whether you are considering establishing a trust, reviewing existing arrangements or planning for the future, our team can help you understand the potential tax implications and make informed decisions.
Getting the right advice from the outset can help protect your wealth and avoid costly mistakes further down the line.
Contact BCR Professional Services to discuss how we can help
What happens when a single mistake in tax advice puts millions of pounds at risk?
In a recent Jersey Royal Court judgment, Representation of B re the Puffin Trust [2026] JRC 233, a trust into which approximately £17.3 million had been transferred was declared invalid after incorrect UK tax advice resulted in substantial unexpected tax liabilities.
The case serves as a cautionary reminder of the importance of getting tax advice right from the outset, particularly when significant wealth and complex financial arrangements are involved.
In April 2018, a woman established a Jersey trust as part of her family's long-term tax and succession planning.
Before establishing the trust, she sought professional advice regarding her UK domicile status. She was advised that she would not become deemed domiciled in the UK until April 2020, allowing her to establish the trust before that date.
However, her adviser had overlooked an earlier period of UK residence. In reality, she had already become deemed UK-domiciled in April 2017.
The mistake was discovered in December 2025, exposing her to substantial unexpected tax liabilities, including an initial inheritance tax charge of approximately £4.245 million and interest of approximately £1.63 million.
The Royal Court accepted that the trust would not have been established had the correct advice been provided. It therefore declared the trust invalid and set aside the transfers made into it.
Although the decision addressed the inheritance tax consequences, certain income tax and capital gains tax liabilities remained.
Read the full Royal Court judgment: Representation of B re the Puffin Trust [2026]JRC 233.
This case highlights how even a seemingly small oversight can have substantial financial consequences.
For individuals with international connections, tax planning can be particularly complex. Residence history, domicile status and the interaction between different tax jurisdictions can all influence the effectiveness of a proposed arrangement.
As the Puffin Trust case demonstrates, failing to consider one important detail can result in millions of pounds in unexpected liabilities.
While the Royal Court was able to provide relief in this instance, such remedies are not guaranteed. Correcting mistakes after financial arrangements have been established can be complicated, costly and time-consuming.
Seeking specialist tax advice before making significant financial decisions can help identify potential risks, avoid unexpected liabilities and ensure that arrangements are appropriate for your circumstances.
At BCR Professional Services, we provide tailored tax advice to individuals, families and businesses, helping them navigate complex UK and Jersey tax considerations.
Whether you are considering establishing a trust, reviewing existing arrangements or planning for the future, our team can help you understand the potential tax implications and make informed decisions.
Getting the right advice from the outset can help protect your wealth and avoid costly mistakes further down the line.
Contact BCR Professional Services to discuss how we can help