Portugal to end its Non-Habitual Resident (“NHR”) Tax Regime from 2024  

Portugal announces end of NHR Tax regime Last week, António Costa stated in an interview that he intends to phase-out the highly beneficial NHR tax regime by 2024. But, for now, there is good news, individuals who have registered for the scheme before 2024 will be able to continue to benefit for the foreseeable future.…

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Is it time to reform IHT? 

It is heavily mooted that Rishi Sunak is going to announce that he plans to significantly reform or possibly abolish inheritance tax (“IHT”). This is likely to be a talking point for quite some time. Therefore, we have provided some context to the potential reform below.   Background  IHT is levied on the death estate according…

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Estate Planning using Double Tax Agreements – Should you be doing more?  

HMRC have successfully challenged a taxpayer’s domicile of choice on death, such that the taxpayer was unable to benefit from the highly beneficial India-UK Double Tax Agreement (“DTA”). This article discusses how the First Tier Tribunal reached their conclusion and highlights the need to ensure that “intentions” can be substantiated on demand.   Inheritance Tax (“IHT”)   …

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HMRC target non-resident corporate landlords

HMRC target non-resident corporate landlords…  HMRC have started sending letters to non-resident corporate landlords owning commercial property in the UK that have not previously filed tax returns.    HMRC suspect that these companies are likely to be in receipt of rental income (or possibly business profits attributable to a permanent establishment) that have not previously been…

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