HMRC has produced guidance on its view on the application of the residence tests in section 69 (2D) Taxation of Chargeable Gains Act 1992 and section 475 (6) Income Tax Act 2007 in relation to overseas trust companies particularly those owned by UK-based groups.

Full details of the guide is available at http://www.hmrc.gov.uk/cnr/trustee-res-guidance.pdf