Ben Symons recently published a case analysis on the decision of the First-tier Tribunal in the case of Louwman v Revenue and Customs Commissioners [2025] UKFTT 295. The case concerned whether OIGs and AIPs arising in offshore protected trusts were protected foreign source income (Louwman v Revenue and Customs Commissioners [2025] UKFTT 295 (TC)) Lexis Nexis PSL (May 2025). The tribunal considered that OIGs and AIPs were not protected foreign source income and that the taxpayer was taxable on them on an arising basis. A potential solution to this problem was to hold mutual funds/bond investments through an opaque entity/company that the trust owns (although this solution may not work in all circumstances and is subject to anti-avoidance rules). Please follow the link below to view the full summary :