Dual Contracts spell Double Trouble

Dual Contracts spell DOUBLE TROUBLE HMRC proposes new legislation on the taxation of dual contracts used by non-domiciles. In his autumn statement the Chancellor, George Osborne, announced plans to  curb tax avoidance using ‘dual contracts’. Dual contracts are a common technique where an employee working for an international employer has several contracts with different group…

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Rumours of extending UK CGT on UK property to Non Residents

There is an extraordinary anomaly when it comes to the taxation of capital gains on UK property. This is because foreign investors are not subject to Capital Gains Tax at all, while UK resident individuals are. At first glance this seems unfair, and there have been recent articles in the press which suggest that George…

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Annual Tax on Enveloped Dwellings (ATED)

Taxation of High Value Residential Property  The Budget on 22nd March 2013 proposed a new annual charge and an extension of Capital Gains Tax to certain ‘non-natural persons’ owning residential property with a value in excess of £2 million, alongside an increase in the stamp duty land tax (“SDLT”) rates. Finance Act 2013 was granted…

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