International

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International guidance:

Until 5 April 2013, ordinary residence was one of three key factors that needed to be considered when deciding whether, or to what extent, an individual was liable to tax...

Practice Note

Increasingly, UK trustees hold foreign assets as part of trust property. This may be because: • they have been put into trust by the original settlor • they form part of...

Practice Note

This Practice Note was originally written by Milestone International Tax Partners LLP but is now maintained by Mourant Ozannes. An offshore trust is a trust where the...

Practice Note

What are the anti-avoidance concerns in a double tax treaty context? As discussed in Practice Note: What are double tax treaties?, one of the aims of double tax...

Practice Note

Application for Grant of Probate Guernsey domiciled testator The probate jurisdiction in Guernsey is administered by the Ecclesiastical Court. The daily business of the...

Practice Note

When a non-Jersey domiciled person dies leaving assets in Jersey with a value of over £10,000, the asset-holder is legally required to request that a Jersey Grant be...

Practice Note

Residence usually refers to the individual's tax status on a year by year basis, however it may be possible to split the tax year into periods of UK residence and...

Practice Note

The eligibility criteria for obtaining a sponsor licence are not located in statute law nor in the Immigration Rules; they are mainly contained within the long and...

Practice Note

Broadly speaking, UK inheritance tax (IHT) is payable on lifetime transfers or on death on any foreign assets owned by an individual domiciled (or deemed domicile) in the...

Practice Note

Why is assistance in collection needed? The background to this topic is the existence of a general rule of international law concerning the fact that generally one...

Practice Note

This Practice Note is about the rules that can impose a charge to tax on UK persons holding interests in a non-UK resident company if that company disposes of an asset...

Practice Note

The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and enforce their own...

Practice Note

The Common Reporting Standard (CRS) is a global standard under which participating jurisdictions agree to exchange information about financial accounts held by...

Practice Note

FORTHCOMING CHANGE: The fifth anti-money laundering directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force on 9 July 2018. The...

Practice Note

This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust companies (PTCs) and...

Practice Note

This Practice Note provides an introduction to the British Virgin Islands (BVI) in the context of offshore trusts. For general information about the BVI, see Practice...

Practice Note