Non-domiciliaries and the remittance basis

Non-domiciliaries and the remittance basis guidance:

The incidence of IHT depends on the domicile of an individual. An individual may be domiciled in the UK under the common law (or private international law) or, for IHT...

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

This Practice Note was originally drafted by Simon Goldring and Ben Harle but is now maintained by Lexis®PSL Private Client. The concepts of domicile and residence are...

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

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: As announced at...

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

STOP PRESS: This Practice Note is being reviewed in light of the changes introduced by section 35 and Schedule 10 to the Finance Act 2018. For further guidance, see...

Practice Note

FORTHCOMING CHANGES: At Budget 2018, the government announced that it will introduce secondary legislation to amend the Income Tax (Pay As You Earn) Regulations 2003,...

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 Overseas Workday Relief (OWR) is a relief from UK income tax for...

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

This Practice Note is an overview of the issues facing non-UK domiciliaries when purchasing a home in the UK with a mortgage. The use of debt to fund home ownership has...

Practice Note