HMRC Certificate of Tax Position? What should you do?

HMRC have started to contact UK taxpayers about their offshore income and gains, showing that the UK’s participation in the Common Reporting Standard (“CRS”) is in full force.  What is the Common Reporting Standard? Over 100 countries have signed up to CRS and information regarding the level of income and gains earned by worldwide taxpayers…

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Why Dutch Sandwiches are off the menu in Overseas Territories and Crown Dependencies

Contrary to popular belief, international tax planning is not so much about avoiding tax. Usually advisers help their clients avoid being taxed more than once on the same profits. Use of Dutch Sandwiches or Subsidiary Companies It is not uncommon for a subsidiary company to pay local tax on its trading revenues, then declare a…

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Protected Trusts – what action should our clients take?

HAVE PROTECTED TRUSTS TURNED INTO FALSE PROMISES? Those worrying about what else has been neglected, whilst the UK government’s attention is wholly fixed on Brexit and infighting, will take no comfort from HM Revenue’s recent statement that offshore income gains are not within the new Protected Trusts regime. Background The introduction of the Deemed Domicile rules for income and capital gains tax from April 2017 ended the unlimited access…

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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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