Difference between revisions of "Main Page"
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− | <big>This | + | <big>This site provides comprehensive information about: |
# Taxation of foreign domiciliaries | # Taxation of foreign domiciliaries | ||
# Taxation of non-residents on UK income and assets | # Taxation of non-residents on UK income and assets | ||
# Taxation of UK residents on foreign income and assets | # Taxation of UK residents on foreign income and assets | ||
− | It is the online version | + | It is the online version of [http://www.kessler.co.uk/taxation-of-foreign-domiciliaries/ ''Taxation of Non-Residents and Foreign Domiciliaries''] by [http://www.kessler.co.uk James Kessler QC]. |
<div style="float: left; width: 33%"> | <div style="float: left; width: 33%"> | ||
<big>'''Contents'''</big> | <big>'''Contents'''</big> | ||
− | |||
− | |||
[[Introduction]] | [[Introduction]] | ||
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:1 [[Foreign Domicile: Tax Policy and Reforms]] | :1 [[Foreign Domicile: Tax Policy and Reforms]] | ||
− | :2 [[ | + | :2 [[Tax Avoidance: Public Debate]] |
:3 [[Domicile]] | :3 [[Domicile]] | ||
− | :4 [[Deemed Domicile | + | :4 [[Deemed Domicile]] |
− | :5 [[ | + | :5 [[Residence of Individuals]] |
− | :6 [[Residence of | + | :6 [[Residence of Trustees]] |
− | :7 [[Residence | + | :7 [[Treaty-Residence]] |
− | :8 [[ | + | :8 [[Exit Taxes]] |
− | :9 | + | :9 [[Split Years: Arrival and Departure]] |
− | :10 [[ | + | :10 [[Temporary Non-residence: Post-2013 Departures]] |
− | : | + | :10A [[Temporary Non-residence: Pre-2013 Departures]] |
− | : | + | :11 [[The Remittance Basis]] |
− | :12 [[The Remittance | + | :12 [[The Meaning of Remittance]] |
− | :13 [[ | + | :13 [[Remittance Reliefs]] |
− | :14 [[ | + | :14 [[Mixed Funds]] |
− | :15 [[ | + | :15 [[Income Categories and Sources]] |
− | :16 [[Income | + | :16 [[Trading Income]] |
− | :17 [[Trading | + | :17 [[Trading in Land]] |
:18 [[Entertainers and Sportspeople]] | :18 [[Entertainers and Sportspeople]] | ||
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:50 [[Investment Manager Exemptions]] | :50 [[Investment Manager Exemptions]] | ||
− | :51 [[ | + | :51 [[Investment Management Fees & Carried Forward]] |
− | :52 [[ | + | :52 [[Loans from Non-Resident Companies]] |
− | :53 [[ | + | :53 [[Rates of Tax]] |
− | :54 [[ | + | :54 [[Personal Allowances and Annual Exemptions]] |
− | :55 [[ | + | :55 [[National Insurance Contributions]] |
− | :56 [[Gains of | + | :56 [[Gains of UK Residents]] |
− | :57 [[ | + | :57 [[Gains of Non-Resident Settlor-Interested Trusts: s.86]] |
− | :58 [[ | + | :58 [[Capital Payments from Non-Resident Trusts: s.87]] |
− | :59 [[ | + | :59 [[Borrowing by Non-resident Trust: Sch 4B]] |
− | :60 [[ | + | :60 [[Protected Trusts]] |
− | :61 [[ | + | :61 [[Sub-Funds]] |
− | :62 [[ | + | :62 [[Gains of Non-Resident Companies]] |
− | :63 [[ | + | :63 [[Capital Losses]] |
− | :64 [[ | + | :64 [[Foreign Currency Issues]] |
− | :65 [[ | + | :65 [[Unremittable Assets]] |
− | :66 [[ | + | :66 [[Double Taxation Arrangements: Introduction]] |
− | :67 [[ | + | :67 [[DTA Anti-abuse Rules]] |
− | :68 [[ | + | :68 [[Foreign Tax Credit Relief]] |
− | :69 [[ | + | :69 [[EU Law and UK Taxation]] |
− | :70 [[ | + | :70 [[Excluded Property: Definition]] |
− | :71 [[ | + | :71 [[Excluded Property Exemptions]] |
− | :72 [[ | + | :72 [[Wills and IOVs]] |
− | :73 [[ | + | :73 [[Reservation of Benefit]] |
− | :74 [[ | + | :74 [[Inter-Trust Transfers: IHT]] |
− | :75 [[IHT | + | :75 [[IHT Deduction for Debts]] |
− | :76 [[IHT | + | :76 [[IHT Double Taxation Treaties - Introduction]] |
− | :77 [[ | + | :77 [[IHT DTAs: India, Pakistan, Italy, France]] |
− | :78 [[ | + | :78 [[IHT DTA: USA]] |
− | :79 [[ | + | :79 [[IHT DTA: Switzerland]] |
− | :80 [[ | + | :80 [[IHT DTA: Netherlands]] |
− | :81 [[ | + | :81 [[Foreign IHT Credit Relief]] |
− | :82 [[ | + | :82 [[Marriage to Non-dom or Non-resident]] |
− | :83 [[ | + | :83 [[Private Residence Relief]] |
− | :84 [[ | + | :84 [[Residential Property of Non-Residents: NRCGT]] |
− | :85 [[ | + | :85 [[Family Home and Chattels: Benefit in Kind Charges]] |
− | :86 [[ | + | :86 [[Corporate Residential Property]] |
− | :87 [[ | + | :87 [[Residential property: IHT]] |
− | :88 [[ | + | :88 [[Pre-Owned Assets]] |
− | :89 [[ | + | :89 [[Joint Accounts]] |
− | :90 [[ | + | :90 [[Estates of Deceased Persons: CGT]] |
− | :91 [[ | + | :91 [[Estates of Deceased Persons: Income Tax]] |
− | :92 [[ | + | :92 [[Who is the Settlor?]] |
− | :93 [[ | + | :93 [[Trusts with Two or More Settlors]] |
− | :94 [[ | + | :94 [[Situs of Assets for IHT]] |
− | :95 [[ | + | :95 [[Situs of Assets for CGT]] |
− | :96 [[ | + | :96 [[Foreign Entities]] |
− | :97 [[ | + | :97 [[Hybrid Entities]] |
− | :98 [[ | + | :98 [[Control Connected Close and Related Expressions]] |
− | :99 [[ | + | :99 [[Permanent Establishment and Branch/Agency]] |
+ | |||
+ | :100 [[Disclosure and Compliance]] | ||
+ | |||
+ | :101 [[Disclosure on Death ]] | ||
+ | |||
+ | :102 [[Disclosure of Offshore Trusts]] | ||
+ | |||
+ | :103 [[Criminal Law and Professional Conduct]] | ||
:[[Appendix 1: Common Expressions]] | :[[Appendix 1: Common Expressions]] | ||
− | :[[Appendix | + | :[[Appendix 2: Consideration, Arm's Length/Full Value]] |
− | :[[Appendix | + | :[[Appendix 3: Associated Operations: IHT]] |
− | :[[Appendix | + | :[[Appendix 4: Construction of Deeming Provisions]] |
− | :[[Appendix | + | :[[Appendix 5: What Do We Mean by "Real"?]] |
− | :[[Appendix | + | :[[Appendix 6: Parliamentarians]] |
− | :[[Appendix | + | :[[Appendix 7: Visiting Forces]] |
− | :[[Appendix | + | :[[Appendix 8: How to Improve Residence and Domicile Taxation]] |
− | :[[Appendix | + | :[[Appendix 9: Reform of Offshore Anti-avoidance Rules]] |
− | :[[Appendix | + | :[[Appendix 10: UK Arrival or Departure: Tax Checklist]] |
+ | :[[Appendix 11: Welsh Devolution]] | ||
</div> | </div> | ||
+ | |||
+ | <big>'''New 2017/18 edition'''</big> | ||
+ | |||
+ | The text is based on the Finance Bill (March 2017) and draft domicile clauses published July 2017. (At present some chapters remain to be updated: this is noted at the top of the chapter where appropriate. Some further formatting work also remains to be completed. However the most important areas are up to date.) | ||
+ | |||
+ | The printed edition of the book, based on the Finance (no.2) Act in its final form, will be published in November, and TFD online will then be updated to the text of the published book. | ||
+ | |||
+ | To access TFD online you will need to order a copy of the new edition and an online licence. To order the book, go to [http://www.khpplc.co.uk/products/91/Taxation-of-Non-Residents-and-Foreign-Domiciliaries the publishers online ordering]; to order a licence go to [http://www.khpplc.co.uk/products/82/Taxation-of-Non-Residents-and-Foreign-Domiciliaries-16th-Online-Edition online ordering] or [mailto:[email protected]?Subject=TFD%20online%20enquiry click here] | ||
+ | |||
+ | Licences for the old edition are no longer valid. | ||
<big>'''How to login'''</big> | <big>'''How to login'''</big> | ||
− | + | Most of this site requires you [[Special:Userlogin|to login]]. To obtain a login licence: | |
− | + | :• Every copy of the printed book has a 3 week trial licence (see inside back cover of volume 1) | |
− | + | :• You may purchase a single or multiple user licence: To obtain these, go to the publishers online ordering [http://www.khpplc.co.uk/products/82/Taxation-of-Non-Residents-and-Foreign-Domiciliaries-15th-Online-Edition here (book)] and [http://www.khpplc.co.uk/products/82/Taxation-of-Non-Residents-and-Foreign-Domiciliaries-15th-Online-Edition here (licence)]. For multiple user licence [mailto:[email protected]?Subject=TFD%20contact%20publisher%20request%20multiple%20user%20licences contact the publishers]. | |
− | + | :• Without logging in, you can access: chap 1 [[Foreign Domicile: Tax Policy and Reforms]]; chap 2 [[Wake Up and Smell the Coffee: Public Debate on Tax Avoidance]]; chap 11A [[Temporary Non-residence: Pre-2013 Departures]]. | |
− | + | ||
− | + | You enter this site once you have registered and [[Special:Userlogin| logged in]] by clicking on the index on the left, or you can search the text. | |
− | You | + | You need to register with the password for the current edition. Registration for an earlier edition is not valid. |
<big>'''How to comment'''</big> | <big>'''How to comment'''</big> | ||
− | Users can also [[contribute to the text | + | Users can also [[contribute to the text]] and if you can add anything extra which is worth saying, or spot anything that needs to be corrected, please do!. A copy of the next edition of the book will be given to the user who makes the most edits. User contributions are reviewed by [http://www.taxchambers.com/barrister/oliver-marre/ Oliver Marre]. |
<big>'''If you want further advice'''</big> | <big>'''If you want further advice'''</big> | ||
− | If you do not find the answer to your question | + | If you do not find the answer to your question here, or if you want advice on which you can legally rely, you may instruct James Kessler QC to advise. See [[How to instruct James Kessler QC]]. |
+ | <big>'''Archive editions'''</big> | ||
− | + | There are [[archive editions]] for years since 2003/04. These will occasionally be useful to investigate the tax position in earlier years, but the current edition will generally be the best starting point, as that has been written in the light of current HMRC guidance, and further thought and research. | |
− | + | ||
− | There are [[archive editions]] for years since | + | |
− | + | ||
<big>'''Contact '''</big> | <big>'''Contact '''</big> | ||
Line 277: | Line 291: | ||
For multiple user licences, or to install on a firm's intranet, [mailto:[email protected]?Subject=TFD%20contact%20publisher%20request%20multiple%20user%20licences contact the publishers]. | For multiple user licences, or to install on a firm's intranet, [mailto:[email protected]?Subject=TFD%20contact%20publisher%20request%20multiple%20user%20licences contact the publishers]. | ||
− | |||
<big>'''Technical notes'''</big> | <big>'''Technical notes'''</big> |
Revision as of 08:53, 17 September 2017
This site provides comprehensive information about:
- Taxation of foreign domiciliaries
- Taxation of non-residents on UK income and assets
- Taxation of UK residents on foreign income and assets
It is the online version of Taxation of Non-Residents and Foreign Domiciliaries by James Kessler QC.
Contents
- 3 Domicile
- 14 Mixed Funds
- 28 PAYE
- 45 Unit Trusts
- 47 Partnerships
- 53 Rates of Tax
- 61 Sub-Funds
- 78 IHT DTA: USA
New 2017/18 edition
The text is based on the Finance Bill (March 2017) and draft domicile clauses published July 2017. (At present some chapters remain to be updated: this is noted at the top of the chapter where appropriate. Some further formatting work also remains to be completed. However the most important areas are up to date.)
The printed edition of the book, based on the Finance (no.2) Act in its final form, will be published in November, and TFD online will then be updated to the text of the published book.
To access TFD online you will need to order a copy of the new edition and an online licence. To order the book, go to the publishers online ordering; to order a licence go to online ordering or click here
Licences for the old edition are no longer valid.
How to login
Most of this site requires you to login. To obtain a login licence:
- • Every copy of the printed book has a 3 week trial licence (see inside back cover of volume 1)
- • You may purchase a single or multiple user licence: To obtain these, go to the publishers online ordering here (book) and here (licence). For multiple user licence contact the publishers.
- • Without logging in, you can access: chap 1 Foreign Domicile: Tax Policy and Reforms; chap 2 Wake Up and Smell the Coffee: Public Debate on Tax Avoidance; chap 11A Temporary Non-residence: Pre-2013 Departures.
You enter this site once you have registered and logged in by clicking on the index on the left, or you can search the text.
You need to register with the password for the current edition. Registration for an earlier edition is not valid.
How to comment
Users can also contribute to the text and if you can add anything extra which is worth saying, or spot anything that needs to be corrected, please do!. A copy of the next edition of the book will be given to the user who makes the most edits. User contributions are reviewed by Oliver Marre.
If you want further advice
If you do not find the answer to your question here, or if you want advice on which you can legally rely, you may instruct James Kessler QC to advise. See How to instruct James Kessler QC.
Archive editions
There are archive editions for years since 2003/04. These will occasionally be useful to investigate the tax position in earlier years, but the current edition will generally be the best starting point, as that has been written in the light of current HMRC guidance, and further thought and research.
Contact
If you have technical problems, or problems logging in, click here
To contact James Kessler QC click here
To contact Oliver Marre, who reviews online contributions, click here
For multiple user licences, or to install on a firm's intranet, contact the publishers.
Technical notes
TFD online is in technical terms a Wiki on the lines of Wikipedia, but only registered users can edit the text.
Site hosting and management by Highwire