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|Published||Second half of 2023|
|Length||ca. 600 pages|
|Suitable for||Accountants, Tax Advisers, Investors|
The concept of domicile and its place in the UK tax systemDomicile of originDomicile of dependencyDomicile of choiceChallenges to general law of domicileDeemed UK domicile
Basis of taxation for UK resident non-UK domiciled individualsAccessing the remittance basisLong-term residents – the remittance basis chargeSourceForeign incomeOverseas workday reliefForeign emolumentsSitus for CGT purposesForeign chargeable gains
Statutory definition of "remitted to the UK"Use directly or indirectly in respect of a relevant debtFinance Act 2008 transitional reliefsRelief for foreign income and gains used to pay the remittance basis chargeBusiness investment reliefRelief for certain UK servicesExempt property relief
SegregationThe mixed fund rulesPunitive mixed fund rulesOverseas workday relief - special rules for nominated account
The current position
Basis of taxation for UK resident individuals with deemed UK domiciledRebasingCleansingTrust protections
Pre-arrival planningLeaving the UKThe temporary non-UK resident provisions
Territorial scope of IHTSitus for IHT purposesApplication of the anti-avoidance legislationPropertyRestriction on spouse exemptionTransferable nil-rate band and residential nil-rate bandIHT estate treaties
Overview of the compliance frameworkRelevant partial closure notices - case lawHMRC "one to many" campaignsInterest and penaltiesMaking a disclosure to HMRCThe general anti-abuse rules
What might the future hold?