Non-domiciliaries and the remittance basis

Non-domiciliaries and the remittance basis guidance:

ARCHIVED: This Practice Note has been archived and is not maintained. The incidence of inheritance tax (IHT) depends on the domicile of an individual. An individual may...

Practice Note

At Summer Budget 2015, the government announced wide-ranging reforms to the deemed domicile rules and also to the excluded property rules as they relate to UK residential...

Practice Note

The concepts of domicile and residence are used to establish the extent of an individual’s liability to UK taxation. Specifically, domicile determines an individual’s...

Practice Note

This Practice Note considers the particular capital loss election that can be made by non-domiciled individuals who claim the remittance basis. For an introduction to the...

Practice Note

A AdministrationThe process starting on the date of the deceased's death and ending on the date the deceased's affairs are finalised by his personal representative(s).See...

Practice Note

This Practice Note summarises the changes to the excluded property rules from 6 April 2017 introduced by the Finance (No 2) Act 2017 (F(No 2)A 2017). Under the changes,...

Practice Note

Based on a Practice Note originally produced by Tolley and Milestone International Tax Partners LLP and now updated by LexisPSL. FORTHCOMING CHANGE relating to IHT: As...

Practice Note

FORTHCOMING CHANGE: As announced at Budget 2018, draft legislation to be included in Finance Bill 2019–20 was published on 11 July 2019 and includes a measure to provide...

Practice Note

The concepts of residence and domicile are used to establish the extent of an individual's liability to UK taxation. This Practice Note provides a summary of the UK...

Practice Note

Before the 2008–09 tax year all UK resident but non-UK domiciled individuals (non-doms) could access the remittance basis of taxation without paying a charge. From 6...

Practice Note

Section 18 of the Inheritance Tax Act 1984 (IHTA 1984) contains an unlimited exemption from inheritance tax (IHT) for transfers of value between spouses and civil...

Practice Note

As discussed in the UK resident non-domiciliaries—tax planning Practice Note, non-domiciled individuals resident in the UK can claim to be taxed on the remittance basis....

Practice Note

A person who is planning to come to the UK should consider the possible tax consequences before he arrives here, so as to maximise the chances of reducing or eliminating...

Practice Note

When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets owned by or for the...

Practice Note

When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets owned by or for the...

Practice Note

When you advise an individual on cross-border or offshore tax planning, it is important to establish the 'source' of income received by or for the individual. This...

Practice Note

Significance of settlor’s domicile for offshore trusts The extent of a trust’s liability to UK income tax and capital gains tax (CGT) depends on the residence status of...

Practice Note

Individuals who are resident and domiciled, or deemed domiciled, in the UK are liable to pay UK income tax on their worldwide income and UK capital gains tax (CGT) on...

Practice Note

Individuals can bring foreign income and capital gains into the UK for the purposes of investment in UK companies without triggering a remittance. This is known as...

Practice Note

Since 6 April 2012 remittance basis foreign income and gains can be brought to the UK to make a qualifying business investment without triggering a remittance basis tax...

Practice Note

A remittance of an individual’s income or chargeable gains will occur if Conditions A and B are met (or if one of Conditions C and D are met). Condition A Condition A is...

Practice Note

To determine whether a remittance has occurred for the purposes of the remittance basis of taxation, reference must be made to the Conditions set out in section 809L of...

Practice Note

Foreign currency accounts at non-UK banks are central to the operation of the remittance basis. See Practice Note: UK resident non-domiciliaries—setting up foreign...

Practice Note

This Practice Note deals with the provisions of section 809L of the Income Tax Act 2007 (ITA 2007) rules as they apply to debts and what constitutes a relevant debt under...

Practice Note

Unfortunately for the practitioner—and indeed the taxpayer—many funds or assets remitted or deemed to be remitted to the UK are not derived from single sources of income...

Practice Note

To determine whether a remittance has occurred for the purposes of the remittance basis of taxation, reference must be made to the Conditions set out in section 809L of...

Practice Note

Individuals who are UK resident and domiciled (or deemed domiciled) are liable to pay UK income tax on their worldwide income and capital gains tax (CGT) on their...

Practice Note

Produced in partnership with Lisa Spearman of Mercer and Hole and Emma Loveday of Wedlake Bell LLP STOP PRESS: On 9 April 2020, a letter from the Chancellor to the Chair...

Practice Note

One of the features of the UK employment income tax rules has long been to afford certain tax advantages to UK resident but non-UK domiciled employees who are able to...

Practice Note

Transfer of Assets Abroad Code The anti-avoidance provisions relating to a transfer of assets abroad are contained in Chapter 2, Part 13 of the Income Tax Act 2007 (ITA...

Practice Note
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