The Spring Budget saw the Chancellor outline his fiscal plans for the UK for the next twelve months based around four key priorities: Employment, Education, Enterprise and Everywhere. Although Mr Hunt’s speech lasted almost an hour, there yet again appears to be very little immediate changes that could impact on our clients. Nevertheless, we have…
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…
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…
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…
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”) …
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…
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