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.…
DetailsIt 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…
DetailsThe polls show that Labour are likely to form the next UK Government. For individuals claiming the remittance basis of taxation in the UK that brings uncertainty as Labour want to abolish the non-domicile (“non-dom”) regime. What is the remittance basis of taxation? Ordinarily, individuals who are tax resident in the UK are taxable on…
DetailsHMRC 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”) …
DetailsHMRC 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…
DetailsRecent cases in the courts underpin how fundamental it is to ensure that intentions regarding domicile, i.e., where a person’s permanent home is, are backed up by facts and actions. Historically, HM Revenue & Customs (“HMRC”) have been known to dispute an individual’s domicile status post-death, and for good reason. Once the taxpayer in question…
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