In July 2015, the Chancellor announced his intention to abolish permanent non-dom status for income tax and capital gains tax with effect from April 2017. Details on these proposals, which first slipped out on 21 September in the form of a Consultation Document (“Condoc”), only to be rapidly removed from HM Treasury’s website, are summarised below. The … Continue reading Non-Dom changes – details slip out
The UK transfer of assets abroad (TOAA) tax regime is designed to prevent individuals using overseas structures to shelter income from UK tax. An example would be an individual who subscribes for shares in an offshore company, arranges for that company to acquire an income-producing asset and accumulate the income from that asset offshore. The … Continue reading Investing abroad – refinement of new exemptions from UK anti-avoidance
Partnerships and LLPs are well established structures for investment funds and business services, popular due to their flexibility and tax transparency. However, the Government is concerned that this flexibility has been abused for tax avoidance purposes and has announced that it will consult on measures to: remove the presumption of self-employment for LLP partners to … Continue reading Partnerships and LLPs – trouble ahead?
Following consultation throughout the summer of 2011, and the publication of draft legislation in December 2011, legislation will be introduced in the Finance Bill 2012 (which will take effect from 6 April 2012) to make certain changes to the taxation of UK-resident non-UK domiciled individuals who elect to be taxed on the remittance basis. In … Continue reading Non-domiciled individuals
In the last Budget the Government announced its intention to introduce a statutory residence test for individuals with effect from April 2012. However, in December 2011, following a public consultation over the summer of 2011, the Government announced that the statutory residence test would instead be enacted in Finance Bill 2013 and take effect in … Continue reading Statutory residence test
A further consultation is announced for 2012 on two specific aspects of the REITs regime. First, the role that REITs can play in supporting the social housing sector. Second, on the treatment of income received by one REIT from another, presumably this is with a view to exemption so that the underlying economics remain the same … Continue reading REITs update
The position, however, for high earners after 2011 will be different. The Government announced at Budget 2009 its intention to restrict tax relief on pensions savings with effect from 6 April 2011 for those with incomes of £150,000 or over. Today it issued a consultation document on how the restriction will be implemented from April … Continue reading Pensions – after 6 April 2011
Several opportunities have been provided to taxpayers ‘to come clean’ about the holding of undeclared offshore assets or bank accounts. These include the 2007 Offshore Disclosure Facility, the New Disclosure Opportunity and the Liechtenstein Disclosure Facility. The final opportunity for disclosure ends on 4 January 2010 (unless another final Facility is introduced (again) or the deadline for … Continue reading Offshore is bad, very bad