Hi Peter Farnell,
Grant Retained Annuity Trust (GRAT) is a non-resident trust.
Please have a look at the guidance at
Non-resident trusts and for more information, contact the trust helpline on 0300 123 1072 (Overseas +44 300 123 1072) or write to HM Revenue & Customs Trusts BX9 1EL.
Thank you.