Offshore anti-avoidance regimes

Offshore anti-avoidance regimes guidance:

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

Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support the self-employed. For more detail, see Practice...

Practice Note

Introduction HMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to income tax and National Insurance contributions...

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

When looking at the definition of chargeable transfers and transfers of value in the Inheritance Tax Act 1984 (IHTA 1984), it is perhaps not immediately apparent that...

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

FORTHCOMING CHANGE: Section 36 of Finance Bill 2019–21 sets out draft changes to the calculation of top-slicing relief such that a taxpayer’s personal allowance is...

Practice Note

The Offshore bonds and other foreign policies Practice Note discusses what is meant by an offshore bond and a foreign policy and it explains the tax charges likely to...

Practice Note

This Practice Note is based on material provided by Tolley and Milestone International Tax Partners LLP, but is now maintained by PSL Private Client. This Practice Note...

Practice Note

STOP PRESS: Following consultation, amendments have been made to the UK rules taxing offshore receipts in respect of intangible property (ORIP) by The Income Tax (Trading...

Practice Note

Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an...

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

Various legislative provisions make up what practitioners often refer to as the 'settlements code'. Part 5, Chapter 5 of the Income Tax (Trading and Other Income) Act...

Practice Note

Capital payments made by an offshore trust to UK resident-domiciled beneficiaries are governed by a series of 'tax hierarchy' rules. The order in which to consider how a...

Practice Note

Income, capital gains and offshore income gains (OIGs) of an offshore trust can all be deemed to accrue to a UK resident beneficiary who receives a capital payment from...

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

When is Sch 4C in point? A Sch 4C pool, ie a pool of gains to which Schedule 4C to the Taxation of Chargeable Gains Act 1992 (TCGA 1992) applies, is created when the...

Practice Note

Major changes to the taxation of offshore trusts were introduced in 2017 and 2018. These changes are summarised in Practice Note: Changes to the taxation of offshore...

Practice Note

Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either: • non-distributor offshore funds, or (after 1st December...

Practice Note

The trustee borrowing rules were introduced in 2000 to counter a specific planning scheme known as a 'flip-flop'. The scheme allowed the settlor of an offshore trust to...

Practice Note

Capital payments are generally taxed by matching them against available relevant income (ARI), offshore income gains (OIGs) and capital gains in that order such that, if...

Practice Note

From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident companies who carry...

Practice Note

Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed are those of...

Practice Note

This Practice Note considers shadow directors of offshore companies and the extent to which such directors may be subject to benefit in kind charges arising under the...

Practice Note

Summary of tax considerations The concept of a close company is intended to capture those companies that are closely controlled (ie by the owners and managers) and...

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

Part 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains key UK anti-avoidance provisions known as the transfer of assets abroad code (TAA Code). The TAA Code...

Practice Note

Transfer of Assets Abroad Code Part 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains a key UK anti-avoidance mechanism known as the Transfer of Assets Abroad...

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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