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”) …
DetailsAlthough the non-dom regime has now been abolished, income and gains sheltered from UK tax under the remittance basis of taxation (“RB”) remain taxable if remitted to the UK. However, between 6 April 2025 until 5 April 2028 there is an amnesty where these funds may be remitted to the UK at a reduced rate…
DetailsThis week The Telegraph reported on recent findings from the Institute of Fiscal Studies which calculates the UK tax burden to be reaching a 70 year high, prompting fears across the political spectrum, of an exodus of the mobile rich to more favourable tax jurisdictions. Further Tax Rises Loom – Mark Davies comments Mark Davies…
DetailsThe first international currency Our logo was inspired by the first international currency and pays tribute to the vision and intrepid entrepreneurship of our international clients. The little owl on our logo is the symbol of Athena, the Greek Goddess of wisdom and Protector of Ancient Athens. This image appeared on a silver coin,…
DetailsThe Pandora Papers were the biggest release of offshore data to date, involving the leak of millions of documents in October 2021 by a number of offshore financial service companies. Letters have been issued to some individuals named in the Pandora Papers Having taken time to review the leaked information, HMRC have now begun the…
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…
Details