Cleansing and rebasing opportunities for non-doms – time to act

A window of opportunity for cleansing and rebasing Those heading for deemed domiciled status have opportunities to protect their assets now through protected trusts, cleansing and rebasing assets. What is a ‘nondom’? A nondom is someone with a foreign (non-UK) domicile. Domicile is a curious concept in English law. It is not the same as tax…

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HMRC Requirement to Correct – how to avoid punitive penalties

The UK has introduced new penalties under the Requirement To Correct (“RTC”). The RTC imposes an obligation on anyone who has under-declared UK tax liabilities to make a disclosure to HM Revenue & Customs (“HMRC”), the UK tax authority. Failure to disclose by 30 September 2018 will result in punitive penalties. The standard penalty is between 100%…

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Mark Davies’ observations on Spain’s IHT reversal for non-EEA residents

Spanish court throws out Spain’s higher IHT for non-EEA residents In a landmark case, the Spanish court has ruled that a long-standing and controversial practice of charging non EEA-residents of Spain inheritance tax is discriminatory and therefore, unlawful. Potentially, this sets the stage for those who have paid inheritance tax in the past to file…

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Mass UK wealth exodus follows non-dom uncertainty

A flight of wealthy individuals leaving the United Kingdom is blamed on growing uncertainty regarding the legal status of non-doms. The trend was discussed by experts at a wealth mobility event in London last month, sponsored by Locate Guernsey, which was attended by more than 100 private wealth advisors. Other reasons for the mass move…

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Budget comment: Mark Davies’ essay in International Investment

        Property Mark Davies is concerned about harsher taxes on property ownership signalled by Finance Act 2018 No. 2. Currently, the UK is a safe place to pay modest income tax, no capital gains tax and no inheritance tax on commercial property. However, Brexit fears are impacting on inward investment to the…

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Mark Davies joins the FT to examine the Autumn Budget 2017

Mark Davies joined the panel of experts at the Financial Times to express his views on the Chancellor’s Autumn Budget. From April 2019, subject to consultation, corporation tax or capital gains tax will be charged on gains made by non-residents on the disposal of UK land and property. “Currently capital gains tax only applies to…

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