Archives by: Jamie Favell

Dual In The Crown: Considering UK and Swiss Dual Resident Status

Our Private Client Tax Partner Jamie Favell was recently featured in the ePrivate Client annual feature on Switzerland discussing the tax implications of being dual resident in the UK and Switzerland. The full content of his article can be viewed here.  [click here to go to the PDF]   For ease we have also copied the full text into this article as follows: Many high net worth individuals have mobile lives which require their advisors to consider the implications of them spending significant time in more than ... Read More

Mixed Fund Cleansing: Action Required

  To recap, if you are a non-dom living in the UK, certain tax residency milestones can impact your tax status. A £30,000 charge applies to access the remittance basis for those who have been resident in the UK for some part of at least 7 out of the previous 9 tax years.  This ‘remittance basis charge’ increases to £60,000 for individuals who have been UK resident in at least 12 of the previous 14 tax years. Since 6 April 2017, a non-dom who ... Read More

HMRC’s Crypto Guidance – New guidance for individuals to be published soon

  THIS ARTICLE HAS BEEN UPDATED ON 21/12/18 - PLEASE FOLLOW THIS LINK   TAP’s governing body the Chartered Institute of Taxation recently attended a meeting of HMRC’s crypto assets roundtable to continue the discussions around the tax treatment of crypto assets. Matters discussed included the current state of the crypto asset market, the Crypto asset Taskforce Report and the new guidance HMRC is preparing. It was confirmed that guidance aimed at individuals will be published shortly, with guidance for businesses following in early 2019. We ... Read More

HMRC’s Requirement to Correct Offshore Tax Irregularities

As previously highlighted, higher HMRC penalties take effect from 1 October this year in relation to ‘offshore’ tax matters. The new regime, known as ‘requirement to correct’ (RTC), imposes some very penal charges where UK tax is found to be underpaid in connection with a jurisdiction outside the UK. That said, to put this in context, where a tax liability is found to be payable in connection with a ‘non-UK’ matter, the default penalty under RTC is 200% of the tax due, and ... Read More

2017 UK–Belarus Double Taxation Convention enters into force

The 2017 UK–Belarus Double Taxation Convention, signed on 26 September 2017, entered into force on 27 July 2018. The Convention takes effect in the UK for: •taxes withheld at source for amounts paid or credited on or after 1 October 2018; •income tax and capital gains tax for any year of assessment beginning on or after 6 April 2019; and •corporation tax for any financial year beginning on or after 1 April 2019. It takes effect in Belarus for: •taxes withheld at source on income derived or ... Read More

Who has a requirement to correct?

It has been well publicised by ourselves, the press and HMRC that the ‘requirement to correct tax due on offshore assets’ ("RTC") needs to be considered and appropriate action taken as necessary before 30 September 2018. HMRC's guidance provides the following detail on when they suggest non-complicance will occur and RTC aaplies: "Offshore non-compliance occurs when there is tax owed to HMRC as a result of tax non-compliance and that non-compliance involves either an offshore matter or an offshore transfer. The tax non-compliance involves ... Read More

Requirement to Correct Offshore Tax Discrepancies

A new punitive offshore penalty regime now applies respect of tax liabilities arising from offshore tax matters. Taxpayers have been given a final ‘opportunity’ to correct any errors for tax years 2016/17 and earlier before 30 September 2018. This opportunity is the ‘Requirement to Correct’ (“RTC”) and any undisclosed offshore tax matters will face a standard eye-watering 200% penalty after that date. The penalty can be reduced to 100% in certain cases. HMRC have made it clear they will target taxpayers using information they ... Read More

Visa Go Go!

It has been reported in the papers that there has been a sharp rise in applications for the UK’s £2M Tier 1 (Investor) Visa. Often referred to as the “Golden VISA” this allows individuals from outside of the EU to come to the UK for 40 months, with an option to extend for a further 2 years. In exchange for the Investor Visa, the applicant must invest £2,000,000 or more in UK government bonds, share capital or loan capital in active and ... Read More

Game, Set & Tax

This year’s Wimbledon winner will net a cool £2.25M in prize money. Not bad for spending a few weeks in the London sun and playing some tennis! But that’s just the cream on the strawberry as they say in SW19… The games stars could be earning endorsement income and bonuses ranging from $5-$30M a year too. Those deals could be in place for endorsing racquets, apparel, watches (usually Swiss!) or for wearing logo'd patches of brands all of who want TV and print ... Read More

Tax Dual Resident : being tax resident in two places at the same time

It is becoming more and more common for expat workers to commute from their home country to another country where they spend their working week. This blog post focuses on how to manage this dual resident situation where the two countries in question have a Double Tax Agreement (‘DTA’) in place. We have a lot of clients, for example, who are resident in the UK and Switzerland, Spain, Germany or the Netherlands. All of whom have a comprehensive DTA in place with the ... Read More
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