Every Cloud has a Silver Lining – TRF – The Temporary Repatriation Facility  

Although 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…

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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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