Dhana Sabanathan

Partner, Michelmores

Dhana is a Partner in the Tax, Trusts and Succession team in London, part of the Firm's private wealth group. She joined Michelmores in 2023 from Winckworth Sherwood, where she was a Partner in the Private Business and Wealth team for over five years, and prior to that a Partner at an international law firm.

Dhana's experience is in the private client and wealth management sector, where she specialises in working with high net worth and ultra-high net worth individuals, family offices, entrepreneurs, corporates and owner-managed businesses. She advises significant family offices and in addition to UK based clients, acts for clients based in Europe, the US, Asia and the Middle East.

'Independently ranked' for Private Wealth Law in the Chambers High Net Worth Guide 2022 and recommended in the Legal 500, Dhana is also recognised in the Citywealth Leaders List as well as Eprivate Client. She is a contributing author at LexisNexis, a member of STEP and on the committee for the STEP City of London branch. She was awarded Silver in the "Woman of the Year – Business Growth Mid Size" category in the 2021 Citywealth Powerwomen Awards.

Dhana regularly writes articles on tax and trust updates (published in the Financial Times) and enjoys speaking at conferences, including hosting an annual conference for our intermediary contacts.

Contributed to

4

Offshore trusts—available relevant income (ARI)

Practice notes

Capital payments made by an offshore trust to UK resident-domiciled beneficiaries are governed by a series of tax hierarchy rules. These rules govern the tax treatment of the amounts received by the beneficiary. The first stage in determining the beneficiary’s tax liability is to ascertain the available relevant income (ARI). This Practice Note by Dhana Sabanathan, partner at Michelmores LLP, considers the ARI legislation (sections 731–735 Income Tax Act 2007 (ITA 2007)) and its practical application.

Private Client

Offshore trusts—matching capital payments where the trustee borrowing rules apply—Sch 4C TCGA 1992

Practice notes

This Practice Note by Dhana Sabanathan, partner at Michelmores LLP, considers Schedule 4C to the Taxation of Capital Gains Act 1992 (TCGA 1992) which comes into operation when, as a result of the rules in TCGA 1992, Sch 4B, non-resident trustees make a transfer of value linked with trustee borrowing.

Private Client

Offshore trusts—the trustee borrowing rules—Sch 4B and Sch 4C TCGA 1992

Practice notes

This Practice Note by Dhana Sabanathan, partner at Michelmores LLP, considers the ‘flip-flop’ tax planning scheme which avoided charges to tax under sections 86 and 87 of the Taxation of Capital Gains Tax Act 1992 (TCGA 1992), and the anti-avoidance rules in Schedules 4B and 4C to TCGA 1992 which were introduced in 2000 to counter the flip-flop scheme.

Private Client

Offshore trusts—transfers between settlements—offshore income gains (OIGs) and s 1(3) amounts

Practice notes

This Practice Note written by Dhana Sabanathan, partner at Michelmores LLP, considers the special provisions contained in section 90 of the Taxation of Capital Gains Act 1992 (TCGA 1992) that apply where all or part of the settled property of a settlement is transferred to another settlement, and the transferor settlement has TCGA 1992, s 1(3) amounts (‘trust gains’) and offshore income gains (OIGs). This note also briefly considers the circumstances in which TCGA 1992, s 90 does not apply.

Private Client