The following Private Client practice note provides comprehensive and up to date legal information covering:
This Practice Note briefly summarises the main UK taxes which may apply to non-UK resident individuals, including income tax, capital gains tax (CGT), inheritance tax (IHT), value added tax (VAT), national insurance contributions (NICs), the annual tax on enveloped dwellings (ATED) and stamp duty land tax (SDLT). Broadly, UK tax legislation is subject to territorial limits, so that either what is taxed must have a UK source, or the person who is taxed, is resident in the UK.
In contrast to many other jurisdictions, the UK tax year is not a calendar year, but runs from 6 April to 5 April.
UK income tax legislation has long recognised the territoriality principle.
The most important exceptions and qualifications are:
The relevant foreign income and certain earnings of remittance basis users are not taxed except insofar as remitted (see Practice Note: UK resident non-domiciliaries—application of the remittance basis to foreign income and gains)
Where there is a double tax agreement, it may provide for certain foreign income and gains to be wholly exempt from UK tax. If not, UK tax is charged, but a claim may be made for a credit to be given against the UK tax for the lower of the overseas tax liability and the UK tax liability. Alternatively, a claim may
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Voluntary manslaughterVoluntary manslaughter consists of those killings which would be murder (because the accused has the relevant mental element for murder) but which are reduced to manslaughter because of one of the three special defences (loss of control, diminished responsibility or suicide
Private nuisancePrivate nuisance is an unlawful interference with a person's use or enjoyment of land or some right over or in connection with it. Interference must be unreasonable, and may be caused, eg by water, smoke, smell, fumes, gas, noise, heat or vibrations. Where the defendant has not
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible fixed assets. Note, however, that certain intangible fixed assets are excluded from the regime, see Practice Note: Excluded intangible fixed
Brexit: The UK's departure from the EU on exit day ie Friday 31 January 2020 has implications for practitioners dealing with provisions in the CPR relevant to cross border matters, including CPR 5.4C (discussed below). For guidance on the impact of Brexit on the CPR, see Cross border
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