While the 2019 Spring Budget was a fairly benign event for private clients, HMRC published a policy paper which is worthy of further commentary and of particular interest to our non-domiciled clients.“No Safe Havens 2019”This paper outlines HMRC’s approach to how they will ensure offshore tax compliance for UK resident taxpayers in order to achieve their objective “to maximise revenues and bear down on avoidance and evasion”.The paper goes on to explain what we already know and that is that the ...Read More
HMRC are currently sending out letters to taxpayers requesting more information on overseas income and gains, which may not have previously been disclosed to HMRC. This letter has been sent because HMRC has received information that suggests you may have overseas income or gains to declare.As you may be aware, information is provided to HMRC from a variety of sources, but these recent letters from HMRC appear to be prompted as a result of information exchange agreements the UK has entered ...Read More
On Friday 7 December 2018 the UK Government suspended the UK Tier 1 (investor) Visa regime at very short notice. These visas allow the right to live in the UK in exchange for investing at least £2m into the UK for a period of 5 years, after which the individual may be eligible for indefinite leave to remain in the UK. The visas have been popular with wealthy individuals from outside the EU and have brought significant funds into the UK ...Read More
This article has been superseded by a government U-turn, follow this link for further information.
The UK’s Tier 1 (Investor) Visa scheme which allows foreign investors to live in the UK is to be suddenly suspended from midnight on Friday 7 December 2018, with the UK Government saying they have concerns that the Visa route has been used for money laundering.Tier 1 (Investor) Visas were introduced in 2008 with some reforms made in 2014. Broadly, they require the holder to invest a ...Read More
In April 2017 significant changes were made to the way in which UK resident but non-UK domiciled individuals (“non-doms”) are taxed in the UK. Broadly, non doms who have been resident in the UK for 15 of the previous 20 tax years are now taxable in the UK on their worldwide income and gains, as well and to inheritance tax on their worldwide assets. The changes to the income tax and capital gains tax rules would, without specific legislation in place, ...Read More
The Chancellor of the Exchequer today announced his final post-Brexit budget. From a personal tax perspective, the Budget contained a number of small changes to existing rules and confirmation of policies already announced but not much new of major significance.As expected, the key announcement in terms of business taxation is the introduction of a Digital Services Tax on very large businesses and partial relief from business rates at the other end of the scale.The key issues are summarised as follows:
Rates and ...Read More
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
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
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
The government has announced its plans to introduce new legislation which will more than double the retrospective time limit during which HMRC can investigate non-payment of income tax, capital gains tax and inheritance tax from offshore accounts where there is “non-deliberate offshore non-compliance”.
Currently, a discovery assessment can be raised up to four years after the end of the tax year in question, which can be extended to six years if HMRC can demonstrate carelessness has been involved. The proposals ...Read More