mumbai as time runs out for swiss bank and other secret offshore accounts of resident indians some of them are hiding behind trust structures to escape tax authoritiesat least three individuals who were ordered to pay tax against money lying in liechtensteins lgt bank have told the tax department that their names figure as beneficiaries of a trust that has an account with the bank the persons said they were neither aware how the trust was formed nor have they received any money from the trust last week all three appealed before tax tribunals to challenge the departments order which had directed each of them to cough up rs 16 crore as tax these three are among the 40 in the list of lgt account holders that german authorities shared with the indian government two years agoit could well be a clever ploy as such offshore discretionary trusts can serve as shelter for possible tax evaders also many account holders are shifting money to dubai said a person who refused to disclose the names of the beneficiaries of the trust concerned according to him many residents who stashed money in big as well as boutique swiss banks like julius baer may have parked the money in the names of discretionary trusts in discretionary trusts the proportion of money to be shared with the beneficiaries is left to the discretion of the trustees and not spelt out in the trust deed nris who have formed such trusts can in no way be touched by indian authorities but as far as residents are concerned it will be interesting to find out how tax tribunals and courts view such an argument about a trust its a hurdle that tax authorities may run into said a mumbaibased senior chartered accountant but in cases where individuals have opened accounts directly the government will come under pressure to reveal the names behind the numbered codes once the indoswiss treaty comes into effect in april in several cases there may be a layer or two between a trust and direct beneficiaries and eventually it may be difficult for tax authorities to legally establish that the money belongs to a particular individual he saidinterestingly in the three cases where tribunals have been moved the underlying trust papers that could have revealed the names of trustees and other details are missing it is learnt that the account was shifted to lgt in 93 from credit suisse the secondlargest swiss bank and the papers were either misplaced or never collectedaccording to chartered accountants and experts on foreign exchange regulations many account holders are shifting money to dubai banks where accounts are opened in names of companies floated in free trade zones in its edition dated december 11 2010 et had reported about the unusual spurt in deposits in uae banks and that a part of the increase may be due to money moving out of swiss banks to dubai since account holders whose names come out after april can be