HMRC failed to apply the 7.5% basic rate dividend tax credit to non-resident trustees in the tax year 2016/17. HMRC has confirmed that it is aware of the issue and that it has resolved the problem for the 2017/18 trust tax calculations, but has not yet confirmed how it intends to respond.

These oversights demonstrate the importance of reviewing self assessment tax returns carefully. It is critical that non-resident trustees take appropriate advice if they feel that they may have been exposed to the error. When even HMRC are prone to such lapses it really does highlight the increasing speed with which the offshore tax landscape has changed.