Non-Dom Tax

HMRC confirms no trust protection for offshore income gains

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

Budget 2018 – summary of key tax announcements

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

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

Discovery Assessment for Offshore Non-Compliance

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

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

Overseas workdays relief – Expat Tax Back

Overseas Workdays Relief (OWDR) is a valuable tax relief available to non-UK domiciled taxpayers, which exempts employment earnings relating to duties performed overseas from a charge to UK tax provided certain conditions are met. If implemented correctly and in the right circumstances the relief can generate very big UK tax repayments. To be eligible for this relief, an individual is required to: • Be UK tax resident in the tax year following three consecutive tax years of non-UK tax residence; • be domiciled outside the ... Read More
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