LTS Tax Limited is an independently owned fi rm of Chartered Tax Advisers based in Guernsey, led by a management team with a combined professional

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3 LTS Tax Limited is an independently owned fi rm of Chartered Tax Advisers based in Guernsey, led by a management team with a combined professional experience of over 100 years. Why LTS Tax? Focus As a specialist fi rm we are able to focus on delivering bespoke tax services combined with practical solutions and a highly personal approach. Expertise All members of our technical team are Chartered Tax Advisers and we have extensive experience across all aspects of the private client, corporate and fi duciary sectors. Value As a small fi rm, we able to offer excellent value for money based on a pragmatic approach and a sensible pricing structure, with fi xed fees available on request.

4 Guernsey personal and corporate tax services We act for a wide range of Guernsey resident private clients and owner-managed businesses and are able to offer full range of personal and corporate tax compliance services. We also provide a local accounts preparation service. Our compliance services include: Guernsey personal and company tax returns preparation; Compliance and reporting services for fund managers; Book-keeping and accounts preparation; Payroll services. Our advisory services include: Emigration and immigration advice; Local residency issues; Tax effi cient structuring for investments; Estate planning and executorship services; Private client services Tax advice for pensions including the taxation implications of contributions and distributions along with transfers to and from schemes such as SIPPS, QROPS, QNUPS, EBTs and EFRBS. \\ The Island comprises 65 square kilometres and is home to over 60,000 people. It offers a pleasant, English speaking jurisdiction, located within easy reach of the UK with a flight time from London taking around 40 minutes and offers a favourable option for individuals looking to relocate from the UK. \\ Guernsey as a jurisdiction Regulatory matters The Guernsey fi nance industry has been servicing private and corporate clients for over 50 years and the Island hosts many international banks, global accountancy fi rms and multijurisdictional law fi rms. There are currently around 150 licensed fi duciary companies in operation. The Island has high regulatory standards and the number of Double Tax Treaties and Tax Information Exchange Agreements (TIEAs) concluded by the authorities is growing continuously and has resulted in Guernsey being regarded as a well-regulated and respected trust and fi duciary centre. Guernsey will report under a Model 1 FATCA agreement with the US. As a result of its close ties with the UK, Guernsey has signed a similar agreement with the UK. In addition, Guernsey has committed to adopt the Common Reporting Standards. Competitive tax environment Individuals are subject to income tax at 20%, whereas most corporate entities are subject to 0% tax. Individuals may be tax capped depending on their sources of income. Non-Guernsey income and Guernsey bank interest accruing to trusts that have no Guernsey benefi ciaries are not subject to Guernsey income tax. There is no withholding tax on dividends paid, no capital gains tax, no death duties, inheritance taxes or stamp duty. Guernsey does not currently levy a VAT or GST system. Guernsey as a location Considered as one of the most reputable and politically stable offshore centres in the world, Guernsey boasts beautiful coastlines and a reputation as an independent and well regulated jurisdiction. Situated approximately 30 miles from the north coast of France and 70 miles from the south coast of England, Guernsey is in the same time zone as the UK and is easily accessible from the major European fi nancial centres. The Island comprises 65 square kilometres and is home to over 60,000 people. It offers a pleasant, English speaking jurisdiction, located within easy reach of the UK with a flight time from London taking around 40 minutes and offers a favourable option for individuals looking to relocate from the UK.

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6 Trust tax services We offer a full range of UK tax compliance and advisory services to local fiduciary providers. Our experienced team has excellent insight into the challenges currently faced by trustees due to the myriad of UK tax legislation. We are able to explain complex tax issues in a clear and concise manner and provide workable, pragmatic solutions where required. Our compliance services include: UK self-assessment returns for trustees; UK self-assessment returns for offshore companies, including rental income calculations; Returns in relation to UK residential property i.e. Annual Tax on Enveloped Dwellings (ATED) returns, ATED-related gains returns and Non-Resident CGT returns; Forms 50(FS), together with analysis (historic or current) of stockpiled gains, relevant income and capital payments; Inheritance tax returns for ten year charges and exit charges; Tax reporting services in relation to settlors and beneficiaries, including claims for relief under Extra Statutory Concession B18 in respect of UK tax paid by trustees; Voluntary disclosures to HM Revenue & Customs regarding historic non-compliance. Our advisory services include: The provision of trust health-check reviews to provide an overview of the current tax status of trust structures and highlight planning opportunities and identify any areas of non-compliance. Structuring advice in relation to the acquisition and holding of assets, including UK residential property; Advice regarding distribution of assets to beneficiaries and capital payment planning; Remittance considerations in relation to UK resident but non UK domiciled individuals and advice in relation to mixed fund bank accounts; Rebasing elections; Advice regarding Employee Benefit Trusts (EBTs) and Employer Financed Retirement Benefit Schemes (EFRBS) including the impact of the Disguised Remuneration legislation and the tax position on extraction of funds; Advice in respect of QROPS, QNUPS and Guernsey RATS as well as all aspects of pension taxation. Identification of international tax exposures across various jurisdictions. In addition, we are able to provide in-house training sessions to promote tax awareness for trust professionals on all aspects of UK tax as required. \\ We are able to explain complex tax issues in a clear and concise manner and provide workable, pragmatic solutions where required. \\ UK personal tax services We have extensive experience in dealing with the tax affairs of individuals who are either UK resident or who have exposure to UK tax in relation to UK assets or other activities and offer a full range of tax compliance and advisory services. In particular, we specialise in providing advice to individuals who are UK resident but non-uk domiciled. Our compliance services include: Self-assessment tax returns; Repayment claims; Non-UK resident CGT returns in respect of UK residential property. Our advisory services include: Advice on residence and domicile matters; Inheritance tax planning; Advice on remittances and related structuring; Remittance basis claims and related matters; Structuring advice in respect of ownership of assets; Advice in relation to trust structures; Emigration and immigration planning.

7 LTS Tax Limited senior management team Simon Graham Managing Director Simon began working in the Guernsey Finance Industry in 1992 at the accountancy practice BDO, after graduating from Newcastle University with a degree in History. At BDO Simon was appointed as a director of the tax and trust companies in 2003 and serviced a varied portfolio of local and offshore clients. Simon is responsible for a wide ranging portfolio of high net worth individuals, trusts and corporate entities with a particular focus on property structures. In addition to acting for various other property clients, between 2003 and 2011 Simon was a director of CPC Group Limited, a Guernsey based privately held company focussed on high value residential property developments and investments. During this time Simon acted for a number of SPV s that were actively involved in several high profile property transactions in London, Monaco and LA, including the acquisitions of the Middlesex Hospital and the Chelsea Barracks and the development of Bowater House into One Hyde Park. Simon has previously served for a number of years on the board of a fund administration business, licensed and regulated by the Guernsey Financial Services Commission, he is a former co-editor of Tolley s Taxation in the Channel Islands and Isle of Man and he is a member of the Chartered Institute of Taxation. Simon is recognised in the Citywealth Leaders List and listed as a Leading Accountant Prominent Figure. E: simon.graham@lts-tax.com Francis Snoding Director Francis began working in the Finance Industry in 1988 and is a qualified Chartered Tax Adviser. After working for a small accountancy practice Francis worked for the Guernsey Tax Authority for six years before joining BDO in 1996, where he became a tax director and a director of the trust company. Francis spent a number of years as a member of BDO s International Tax Centre of Excellence dealing with cross border taxation of international private clients, attending and speaking at conferences across Europe. Francis is a member of the Taxation Sub Committee of the Guernsey Society of Chartered and Certified Accountants and has contributed technical articles to a number of publications for many years. Francis recently sat on a committee alongside the Guernsey Income Tax Office during the process of modernising the Guernsey tax law as applicable to pensions. Francis is responsible for a portfolio of high net worth individuals, trust and company structures, QROPS and pension schemes. Francis is recognised in the Citywealth Leaders List as a Leading Accountant Prominent Figure and note him as being the best person to go to in Guernsey for Tax and related advice. E: fran.snoding@lts-tax.com Paul O Neill Director Paul began working in the Finance Industry in 2001 after graduating from the University of Ulster with a Law degree. Paul qualified as a Chartered Tax Adviser in 2005 and is also a member of the Association of Tax Technicians. Paul s career commenced with PricewaterhouseCoopers in Guernsey and resulted in Paul moving to PwC s Investment Management and Real Estate Team in London where he was responsible for providing tax advice on funds and Real Estate Structures. On his return to Guernsey Paul joined BDO Tax Limited where he was promoted to director in the Private Client Department. In addition to this Paul assumed responsibility for business development in the MENA Region which included spending six months in the Middle East and retaining responsibility for growth in the Region on his return to Guernsey. Paul is responsible for a wide ranging portfolio of high net worth individuals, trusts, charitable trusts and corporate entities. Paul is recognised in Private Client Practitioner s Top 35 under 35 list and also Citywealth magazine s Guernsey Future Leaders. E: paul.oneill@lts-tax.com Mandy Connolly Associate Director Mandy began her tax career in London in 1988 with Moore Stephens where she qualified as a Chartered Tax Advisor, followed by a move to Smith & Williamson s Private Client and Trust department, also based in London. Mandy moved to Guernsey in 2000 and spent 10 years with a local fiduciary company providing in-house UK tax services to its client base. Mandy moved to EY in 2011 and became Head of Private Client and Trust, specialising in providing tax advisory services to local fiduciaries and individuals on a wide range of complex UK tax issues with a particular emphasis on matters related to UK resident but non UK domiciled individuals. Mandy also has considerable experience of dealing with the tax treatment of employee benefit trusts and Employer Financed Retirement Benefit Schemes as well as all aspects of pension taxation. Mandy joined LTS Tax Limited in 2015 as an associate director and will be primarily responsible for the provision of UK tax services to a portfolio of high net worth individuals and local trust companies. E: mandy.connolly@lts-tax.com

8 PO Box 20, 11 New Street, St Peter Port, Guernsey, GY1 4AN, Channel Islands T: +44 (0) F: +44 (0) E: LTS Tax Limited (registration number: 54292) is registered with the Chartered Institute of Taxation as a fi rm of Chartered Tax Advisers. Please see our website for details. Registered offi ce: 11 New Street, St Peter Port, Guernsey, GY1 2PF.

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