The Court of Sessions in Scotland have overturned previous Tribunal decisions and found in favour of HM Revenue & Customs. The judges have decided that payments by Rangers FC to the principal trust of an employee benefit trust amount to “a mere redirection of emoluments and earnings” and therefore were subject to income tax and…
DetailsMark Davies, Jon Elphick and Nick Beresford consider the benefits of unwinding an existing offshore structure. KEY POINTS What is the issue? Further changes are being introduced that will result in offshore structures owning UK residential property becoming less attractive from a tax perspective. What does it mean for me? These structures need to be reviewed to…
DetailsRecent figures obtained via a Freedom of Information Act request show that take up of Business Investment Relief rose dramatically in the year 2013-2014. Figures obtained by Mark Davies & Associates show that funds invested in the UK under BIR rose by 65% to £545m (rounded to nearest million), meaning that BIR claimants invested an…
DetailsSummary of Consultation Paper issued 30 September 2015 Government’s stated policy aims:- Persons who are UK resident in 15 out of the last 20 tax years will become “deemed domiciled”. They will pay tax on their worldwide personal income and gains, but foreign income and gains sheltered within an offshore trust will escape taxation. Persons…
DetailsFinancial Times comments on Treasury’s proposals on non-dom reform
The amount required to qualify for a UK investor visa has doubled since 2014 and there is fierce competition from other EU states. click here
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