Difference between revisions of "Main Page"

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:48  [[Non-Residents Income Tax Relief]]
 
:48  [[Non-Residents Income Tax Relief]]
  
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:44 [[Collection of Tax from UK Representatives]]
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:49 [[Collection of Tax from UK Representatives]]
  
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:45 [[Investment Manager Exemptions]]
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:50 [[Investment Manager Exemptions]]
  
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:46 [[Loans from Non-Resident Companies]]
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:51 [[Loans from Non-Resident Companies]]
  
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:47 [[Rates of Tax]]
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:52 [[Rates of Tax]]
  
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:48 [[Personal Allowances and Annual Exemptions]]
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:53 [[Personal Allowances and Annual Exemptions]]
  
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:49 [[National Insurance Contributions]]
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:54 [[National Insurance Contributions]]
  
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:50 [[Capital Gains of UK Residents]]
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:55 [[Capital Gains of UK Residents]]
  
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:51 [[Gains of Non-Resident Settlor-Interested Trusts: s.86]]
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:56 [[Gains of Non-Resident Settlor-Interested Trusts: s.86]]
  
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:52 [[Capital Payments from Non-Resident Trusts: s.87]]
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:57 [[Capital Payments from Non-Resident Trusts: s.87]]
  
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:53 [[Borrowing by Non-resident Trust: Sch 4B]]
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:58 [[Borrowing by Non-resident Trust: Sch 4B]]
  
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:54 [[Gains of Non-Resident Companies]]
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:59 [[Gains of Non-Resident Companies]]
  
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:55 [[Capital Losses]]
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:60 [[Capital Losses]]
  
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:56 [[Foreign Currency Issues]]
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:61 [[Foreign Currency Issues]]
  
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:57 [[Unremitted Income: Exchange Control]]
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:62 [[Unremitted Income: Exchange Control]]
  
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:58 [[Double Taxation Agreements: Introduction]]
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:63 [[Double Taxation Arrangements: Introduction]]
  
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:59 [[Foreign Tax Credit Relief]]
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:64 [[DTA Anti-abuse Rules
  
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:60 [[EU Law and UK Taxation]]
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:65 [[Foreign Tax Credit Relief]]
  
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:61 [[Deemed Domicile for IHT]]
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:66 [[EU Law and UK Taxation]]
  
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:62 [[Excluded Property for IHT]]
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:67 [[Excluded Property: Definition]]
  
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:63 [[Reservation of Benefit]]
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:68 [[Excluded Property Exemptions]]
  
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:64 [[IHT Consequences of Transfers Between Trusts]]
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:69 [[Wills and IOVs]]
  
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:65 [[IHT Deduction for Debts]]
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:70 [[Reservation of Benefit]]
  
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:66 [[IHT Planning Before and After a Change of Domicile]]
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:71 [[IHT Consequences of Transfers Between Trusts]]
  
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:67 [[IHT on Death: Wills and IOVs]]
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:72 [[IHT Deduction for Debts]]
  
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:68 [[Double Inheritance Taxation: Introduction]]
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:73 [[Double Inheritance Taxation: Introduction]]
  
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:69 [[IHT DTTs India, Pakistan, Italy, France]]
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:74 [[IHT DTTs India, Pakistan, Italy, France]]
  
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:70 [[IHT DTT USA]]
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:75 [[IHT DTT USA]]
  
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:71 [[IHT DTT Switzerland]]
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:76 [[IHT DTT Switzerland]]
  
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:72 [[Foreign IHT Credit Relief]]
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:77 [[Foreign IHT Credit Relief]]
  
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:73 [[Marriage with Foreign Domiciliary or Non-Resident]]
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:78 [[Marriage with Non-dom or Non-resident]]
  
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:74 [[Residential Property of Non-Residents: NRCGT]]
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:79 [[Private Residence Relief]]
  
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:75 [[The Family Home and its Chattels: Benefit in Kind Charges]]
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:80 [[Residential Property of Non-Residents: NRCGT]]
  
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:76 [[Corporate Residential Property]]
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:81 [[Family Home and Chattels: Benefit in Kind Charges]]
  
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:77 [[Pre-Owned Assets]]
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:82 [[Corporate Residential Property]]
  
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:78 [[Joint Accounts]]
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:83 [[Pre-Owned Assets]]
  
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:79 [[Estates of Deceased Persons: CGT]]
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:84 [[Joint Accounts]]
  
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:80 [[Estates of Deceased Persons: Income Tax]]
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:85 [[Estates of Deceased Persons: CGT]]
  
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:81 [[Who is the Settlor?]]
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:86 [[Estates of Deceased Persons: Income Tax]]
  
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:82 [[Trusts with Two or More Settlors]]
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:87 [[Who is the Settlor?]]
  
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:83 [[Situs of Assets for IHT]]
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:88 [[Trusts with Two or More Settlors]]
  
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:84 [[Situs of Assets for CGT]]
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:89 [[Situs of Assets for IHT]]
  
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:85 [[Foreign Entities]]
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:90 [[Situs of Assets for CGT]]
  
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:86 [[Control Connected Close and Related Expressions]]
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:91 [[Foreign Entities]]
  
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:87 [[Permanent Establishment & Branch/Agency]]
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:92 [[Hybrid Entities]]
  
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:88 [[Disclosure and Compliance]]
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:93 [[Control Connected Close and Related Expressions]]
  
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:89 [[Swiss Tax Agreement Introduction]]
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:94 [[Permanent Establishment and Branch/Agency]]
  
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:90 [[STA Clearance Facility]]
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:95 [[Disclosure and Compliance]]
  
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:91 [[STA Withholding Tax]]
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:96 [[Disclosure and Compliance: IHT]]
  
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:92 [[Disclosure of Information by Swiss Authorities]]
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:97 [[Swiss Tax Agreement Introduction]]
  
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:93 [[Criminal Law and Professional Conduct]]
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:98 [[Criminal Law and Professional Conduct]]
  
 
:[[Appendix 1: Terminology]]
 
:[[Appendix 1: Terminology]]
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:[[Appendix 5: Visiting Forces]]
 
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:[[Appendix 6: Students]]
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:[[Appendix 6: How to Improve Residence and Domicile Taxation]]
  
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:[[Appendix 7: Entertainers and Sportspeople]]
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:[[Appendix 7: Reform of Non-Residence Anti-avoidance Rules]]
  
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:[[Appendix 8: How to Improve Residence and Domicile Taxation]]
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:[[Appendix 8: Issues to Consider Before UK Arrival or Departure: Checklist]]
  
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:[[Appendix 9: Reform of Non-Residence Anti- Avoidance Rules]]
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:[[Appendix 9: Welsh Devolution]]
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:[[Appendix 10: Issues to Consider Before UK Arrival or Departure: Checklist]]
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:[[Appendix 11: Travel Expenses: Employment Income Deduction]]
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Revision as of 13:18, 13 July 2016

This website provides comprehensive information about:

  1. Taxation of foreign domiciliaries
  2. Taxation of non-residents on UK income and assets
  3. Taxation of UK residents on foreign income and assets

It is the online version of the book Taxation of Non-Residents and Foreign Domiciliaries by James Kessler QC


Contents

Updates

Introduction

1 Foreign Domicile: Tax Policy and Reforms
2 Wake Up and Smell the Coffee: Public Debate on Tax Avoidance
3 Domicile
4 Deemed Domicile for IHT
5 Deemed Domicile from 2017
6 Residence of Individuals
7 Residence of Trustees
8 Treaty-Residence
9 Exit Taxes
10 Split Years: Arrival and Departure
11 Temporary Non-residence: Post-2013 Departures
11A Temporary Non-residence: Pre-2013 Departures
12 The Remittance Basis
13 The Meaning of Remittance
14 Remittance Reliefs
15 Mixed Funds
16 Income Categories and Sources
17 Trading Income
18 Entertainers and Sportspeople
19 Property Income
20 Deduction of interest from Property Income
21 Interest Income
22 Exempt Interest of Non-Residents
23 Dividend Income
24 Royalty Income
25 Mis Sweep-Up Income
26 Employment Income
27 Travel Expenses: Employment Income Deduction
28 PAYE
29 Employment Income: DT Relief
30 Pension and Annuity Income
31 Discretionary Trusts: Income Tax
32 IIP Trusts: Income Tax
33 Settlor-interested Trusts
34 Transfer of Assets Abroad: Introduction
35 Transfer of Assets Abroad: Transferors
36 Transfer of Assets Abroad: Non-transferors
37 Transfer of Assets Abroad: Relief from Overlapping Charges
38 Transfer of Assets Abroad: Motive Defence
39 Life Policies and Contracts
40 Offshore Funds - Definition
41 Offshore Income Gains
42 Income from Offshore Funds
43 Accrued Income Profits
44 Deeply Discounted Securities
45 Unit Trusts
46 Intermediated Securities
47 Partnerships
48 Non-Residents Income Tax Relief
49 Collection of Tax from UK Representatives
50 Investment Manager Exemptions
51 Loans from Non-Resident Companies
52 Rates of Tax
53 Personal Allowances and Annual Exemptions
54 National Insurance Contributions
55 Capital Gains of UK Residents
56 Gains of Non-Resident Settlor-Interested Trusts: s.86
57 Capital Payments from Non-Resident Trusts: s.87
58 Borrowing by Non-resident Trust: Sch 4B
59 Gains of Non-Resident Companies
60 Capital Losses
61 Foreign Currency Issues
62 Unremitted Income: Exchange Control
63 Double Taxation Arrangements: Introduction
64 [[DTA Anti-abuse Rules
65 Foreign Tax Credit Relief
66 EU Law and UK Taxation
67 Excluded Property: Definition
68 Excluded Property Exemptions
69 Wills and IOVs
70 Reservation of Benefit
71 IHT Consequences of Transfers Between Trusts
72 IHT Deduction for Debts
73 Double Inheritance Taxation: Introduction
74 IHT DTTs India, Pakistan, Italy, France
75 IHT DTT USA
76 IHT DTT Switzerland
77 Foreign IHT Credit Relief
78 Marriage with Non-dom or Non-resident
79 Private Residence Relief
80 Residential Property of Non-Residents: NRCGT
81 Family Home and Chattels: Benefit in Kind Charges
82 Corporate Residential Property
83 Pre-Owned Assets
84 Joint Accounts
85 Estates of Deceased Persons: CGT
86 Estates of Deceased Persons: Income Tax
87 Who is the Settlor?
88 Trusts with Two or More Settlors
89 Situs of Assets for IHT
90 Situs of Assets for CGT
91 Foreign Entities
92 Hybrid Entities
93 Control Connected Close and Related Expressions
94 Permanent Establishment and Branch/Agency
95 Disclosure and Compliance
96 Disclosure and Compliance: IHT
97 Swiss Tax Agreement Introduction
98 Criminal Law and Professional Conduct
Appendix 1: Terminology
Appendix 2: Construction of Deeming Provisions
Appendix 3: What Do We Mean by "Real"?
Appendix 4: Parliamentarians
Appendix 5: Visiting Forces
Appendix 6: How to Improve Residence and Domicile Taxation
Appendix 7: Reform of Non-Residence Anti-avoidance Rules
Appendix 8: Issues to Consider Before UK Arrival or Departure: Checklist
Appendix 9: Welsh Devolution



TFD 2016/17 edition out soon

The new 2016/17 edition of "Taxation of Non-residents and Foreign Domiciliaries" will be published online on 1 September 2016. The text will be based on the Finance Bill as it then stands. The printed edition of the book, based on the Finance Act in its final form, will be published in October and at that time the online edition will be updated.

To maintain unbroken access to TFD online you will need a copy of the new edition with an online licence. To obtain these, go to the publishers online ordering here (book) and here (licence)

Online licences for the current edition will not be valid from 1 September 2015 when the new edition is published.


About TFD Online

Most of this website 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 user online licence (£99 + VAT with a copy of the book) or a multiple user licence: To obtain the book and online licence, go to the publishers online ordering and search for Kessler. For multiple user licence contact the publishers.

3 chapters can be accessed without a login: chapters 1 and 2 (which concern policy issues of general interest) and 9A (on a transitional issue which is not set out in full in the printed book).

If you registered before the current edition was published in September 2015, you need to reregister with a password for the current edition. However, if you have not (yet) bought the book you may register for a free one day trial. There is no charge for a one day trial, but if you find the site useful, and wish to express support or thanks, you are invited to make a donation to the charity Water Aid.

You may enter this site once you have registered and logged in by clicking on the index below, or you can search the text.

Users can also contribute to the text and correct slips or errors and if you see anything that needs correcting or expanding, 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.

The initial data was the current edition of Taxation of Non-residents and Foreign Domiciliaries published 1 September 2015.

There have been significant updates since the book went to print. For the list see here.


If you want further advice

If you do not find the answer to your question in TFD online, or if you want advice on which you can legally rely, you may instruct James Kessler QC to advise. For further information see How to instruct James Kessler QC.


TFD archive editions

There are archive editions for years since 2008/09. 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 this wiki.

Site hosting and management by Highwire

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