Edition 1st
Published February 2023
Length 600pp est.
Suitable for Accountants, Tax Advisers, Investors
Price 95
ISBN 9781912386659

Non-UK domiciled individuals

£95.00


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Non-UK domiciled individuals UK Tax Compliance and Planning

A practical guide to the complexities of the UK tax system as it pertains to non-UK domiciled individuals. The book will include a thorough discussion of the law and of the relevant compliance issues. Tax mitigation strategies will be considered and traps in the legislation will be highlighted. 

Throughout the book there will be examples and case studies to illustrate the points made.

The focus of the book will be UK resident non-UK domiciled individuals. However, the territorial scope of UK legislation and its impact on non-UK resident and non-UK domiciled individuals will also be considered.  

Lynnette Bober MA (Cantab), MA in Law, BFP, FCA, CTA, TEP, MCIArb was called to the Bar in March 2021. She is a Tax Director at Gateley Legal. Read more here.

DOMICILE AND WHY IT MATTERS FOR UK TAX PURPOSES
  • The concept of domicile and its place in the UK tax system
  • Domicile of origin
  • Domicile of dependency
  • Domicile of choice
  • Challenges to general law of domicile
  • Deemed UK domicile
INCOME TAX AND CGT FUNDAMENTALS
  • Basis of taxation for UK resident non-UK domiciled individuals
  • Accessing the remittance basis
  • Long-term residents the remittance basis charge
  • Source
  • Foreign income
  • Overseas workday relief
  • Foreign emoluments
  • Situs for CGT purposes
  • Foreign chargeable gains
INCOME TAX AND CGT REMITTED TO THE UK
  • Statutory definition of "remitted to the UK"
  • Use directly or indirectly in respect of a relevant debt
  • Finance Act 2008 transitional reliefs
  • Relief for foreign income and gains used to pay the remittance basis charge
  • Business investment relief
  • Relief for certain UK services
  • Exempt property relief
INCOME TAX AND CGT THE MIXED FUND RULES
  • Segregation
  • The mixed fund rules
  • Punitive mixed fund rules
  • Overseas workday relief - special rules for nominated account
TRUSTS SPECIAL RULES FOR NON-UK DOMICILED INDIVIDUALS
  • The current position
DEEMED DOMICILED INDIVIDUALS
  • Basis of taxation for UK resident individuals with deemed UK domiciled
  • Rebasing
  • Cleansing
  • Trust protections
COMING TO AND LEAVING THE UK
  • Pre-arrival planning
  • Leaving the UK
  • The temporary non-UK resident provisions
INHERITANCE TAX
  • Territorial scope of IHT
  • Situs for IHT purposes
  • Application of the anti-avoidance legislation
  • Property
  • Restriction on spouse exemption
  • Transferable nil-rate band and residential nil-rate band
  • IHT estate treaties
COMPLIANCE / TAX ADMINISTRATION ISSUES
  • Overview of the compliance framework
  • Relevant partial closure notices - case law
  • HMRC "one to many" campaigns
  • Interest and penalties
  • Making a disclosure to HMRC
  • The general anti-abuse rules
CRYSTAL BALL GAZING
  • What might the future hold?

Table of primary legislation
Table of statutory instruments
Index of cases
General index