The following Employment Tax guidance note Produced by Tolley in association with Paul Tew provides comprehensive and up to date tax information covering:
UK resident individuals who are non-UK domiciled can benefit from the remittance basis of taxation. The remittance basis allows for relief from UK taxation for non-UK sources of income which are not brought in (or remitted) to the UK. A remittance is any money or other property which is, or which derives from, offshore income and gains which are brought, either directly or indirectly, into the UK for the benefit of an individual. A remittance also includes any money or other property which derives from offshore income and gains which are for the benefit of any other relevant person.
Generally, an individual has to elect for the remittance basis to apply. There are, though, specific situations when the remittance basis applies automatically, and this guidance note considers these provisions, and how they differ from the general position where an election is required.
Generally, an individual who is UK-resident but not UK-domiciled for a tax year is taxed on the arising basis unless, when completing their self assessment tax return, they make a claim under ITA 2007, s 809B for the remittance basis to apply.
Claiming the remittance basis allows relief from UK tax on income and gains paid and retained outside the UK. It should be remembered; however, that in most cases, there is a tax ‘cost’ in claiming the remittance basis ― namely the loss of personal allowances and reliefs and the CGT annual exempt amount. That being said, for individuals whose income is of a level whereby the personal allowance is completely removed (£125,000 for tax year 2019/20) and where no UK capital gains arise, this ‘cost’ may not be relevant.
Longer term UK residents must also pay the Remittance Basis Charge (RBC) if they wish to be assessable on the remittance basis. The RBC for 2015/16 onwards is £30,000 for an individual who has been UK resident for seven out of the nine prior
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
IntroductionUK tax must be withheld on UK payments including:•interest•royalties•rental incomeWithholding tax may be reduced under double tax treaties (DTT) or European directives, both of which may be subject to making a formal claim.This guidance note outlines the rules for UK withholding tax, and
IntroductionUK resident individuals who are non-UK domiciled can benefit from the remittance basis of taxation. The remittance basis allows for relief from UK taxation for non-UK sources of income which are not brought in (or remitted) to the UK. A remittance is any money or other property which is,
Duty to prepare trust accountsUnder the laws of England and Wales, trustees have a duty to account to the beneficiaries for their financial administration of the trust fund. This duty is established by a substantial body of case law. In the case of Armitage v Nurse, Millett LJ stated:“Every
This guidance note considers the capital gains tax implications where shares are sold in exchange for new shares.The consideration paid by a purchasing company to the shareholder(s) for their shares in a target company could be in the form of either:•new shares in the vendor in exchange for shares
To view our latest tax guidance content, sign in to Tolley Guidance or register for a free trial.