Maya Forstater

Historically three tax advantages in holding UK residential property via offshore trust: stamp duty, inheritance tax and capital gains. 2/x

The stamp duty advantage was nullified by ATED, which imposes an annual charge on "envelopes" property. 3/x

The capital gains advantage was cancelled by legislation two years ago. The inheritance tax advantage killed last year. All sensible. 4/x

So why hold in an offshore trust? Perhaps privacy. Perhaps to circumvent foreign mandatory inheritance rules. But no tax advantage 5/x

So faced with this new levy, you'd either hold directly or via a trust/entity in a non-blacklist jurisdiction. 6/x

No tax cost in doing so. May be a good policy outcome in that may stop beneficial ownership being hidden. But nobody will pay this tax. 7/x

So where does the £3.5bn estimate come from? No clue. But query if it comes from the era when offshore trusts still had tax advantages. 8/x

Either way, this stands as the first tax proposal I've seen which is almost guaranteed to raise zero revenue. Marvellous. 9/9