A number of newspapers over the weekend carried stories regarding the establishment of a specialist HMRC unit to investigate the use of so called family investment companies. The articles are decidedly light on detail and, indeed, HMRC admits that their investigations are only at an exploratory stage. Nevertheless, the existence of such a unit is indicative of HMRC's prevailing attitude to the tax treatment of these (and other) family structures.
Of course, it is worth remembering that the principal purpose of family investment companies is to set aside family wealth for future generations in a constructive and controlled fashion. In years gone by, this could be achieved with the help of family trusts. Perhaps this is something that should be borne in mind by the government as it considers how to respond to the recent All-Party Parliamentary Group report on Inheritance and Intergenerational Fairness?
The UK’s tax authority has created a secretive unit to investigate the use of family investment companies by the very wealthy to avoid inheritance tax, putting family offices with an estimated $1tn-plus in assets in its sights.