Difference between revisions of "Main Page"
| Line 15: | Line 15: | ||
[[Introduction]] | [[Introduction]] | ||
| − | + | ''Non-dom policy & avoidance'' | |
:1 [[Foreign Domicile: Tax Policy]] | :1 [[Foreign Domicile: Tax Policy]] | ||
| Line 21: | Line 21: | ||
:2 [[Tax Avoidance]] | :2 [[Tax Avoidance]] | ||
| − | + | ''Domicile & residence'' | |
:3 [[Domicile]] | :3 [[Domicile]] | ||
| Line 43: | Line 43: | ||
:12 [[UK Arrival or Departure: Tax Checklist]] | :12 [[UK Arrival or Departure: Tax Checklist]] | ||
| − | + | ''Income Tax: Principles & remittance basis'' | |
:13 [[Income Categorisation]] | :13 [[Income Categorisation]] | ||
| Line 49: | Line 49: | ||
:14 [[Income Recognition: Receive/Entitled/Arise/Paid]] | :14 [[Income Recognition: Receive/Entitled/Arise/Paid]] | ||
| + | :15 [[Source/RFI/Territorial Principles]] | ||
| + | :16 [[The Remittance Basis]] | ||
| + | :17 [[The Meaning of Remittance]] | ||
| − | : | + | :18 [[Remittance Reliefs]] |
| − | : | + | :19 [[Mixed Funds]] |
| − | + | ''Income by category'' | |
| − | : | + | :20 [[Trading Income]] |
| − | : | + | :21 [[Trading in Land]] |
| − | : | + | :22 [[Performers]] |
| − | : | + | :23 [[Property Income]] |
| − | : | + | :24 [[Deduction of interest from Property Income]] |
| − | : | + | :25 [[Interest Income]] |
| − | : | + | :26 [[Exempt Interest of Non-Residents]] |
| − | : | + | :27 [[Accrued Income Profits]] |
| − | : | + | :28 [[Deeply Discounted Securities]] |
| − | : | + | :29 [[Dividend Income]] |
| − | : | + | :30 [[Annual Payments]] |
| − | : | + | :31 [[Intellectual Property Income]] |
| − | : | + | :32 [[Misc Sweep-Up Income]] |
| − | : | + | :33 [[Employment Income]] |
| − | : | + | :34 [[Travel Expenses: Employment Income]] |
| − | : | + | :35 [[PAYE]] |
| − | : | + | :36 [[Employment Income: DT Relief]] |
| − | : | + | :37 [[Pension and Annuity Income]] |
| − | : | + | ''IT: General |
| − | : | + | :38 [[Discretionary Trusts: Income Tax]] |
| − | : | + | :39 [[IIP Trusts: Income Tax]] |
| − | : | + | :40 [[Rates of Income Tax/CGT]] |
| − | : | + | :41 [[Personal Allowances]] |
| − | : | + | :42 [[Non-Resident Income Tax Relief]] |
| − | : | + | :43 [[National Insurance Contributions]] |
| − | + | ''IT avoidance codes'' | |
| − | : | + | :44 [[Settlor-interested Trust Code]] |
| − | : | + | :45 [[Transfer of Assets Abroad: Introduction]] |
| − | : | + | :46 [[Transfer of Assets Abroad: Transferors]] |
| − | : | + | :47 [[Transfer of Assets Abroad: Benefits]] |
| − | : | + | :48 [[Transfer of Assets Abroad: Relief from Overlapping Charges]] |
| − | : | + | :49 [[Transfer of Assets Abroad: Motive Defence]] |
| − | : | + | :50 [[Profit Fragmentation]] |
| − | : | + | :51 [[Transfer of Income Streams]] |
| − | : | + | :52 [[Transactions in Securities]] |
| − | + | ''Capital Gains Tax'' | |
| − | : | + | :53 [[Chargeable Gains]] |
| − | : | + | :54 [[UK Property Held by Non-Residents]] |
| − | : | + | :55 [[Residential Property: CGT]] |
| − | : | + | :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 [[Sub-Funds]] |
| − | : | + | :60 [[Gains of Non-Resident Companies]] |
| − | : | + | :61 [[Capital Losses]] |
| − | + | ''Funds'' | |
| − | : | + | :62 [[Life Policies and Contracts]] |
| − | : | + | :63 [[Offshore Funds: Definitions]] |
| − | : | + | :64 [[Offshore Income Gains]] |
| − | : | + | :65 [[Income from Offshore Funds]] |
| − | : | + | :66 [[Unit Trusts]] |
| − | : | + | :67 [[Intermediated Securities]] |
| − | : | + | :68 [[Investment Manager Exemptions]] |
| − | : | + | :69 [[Investment Management Fees & Carried Interest]] |
| − | + | ''Inheritance Tax'' | |
| − | : | + | :70 [[IHT Terms and Concepts]] |
| − | : | + | :49 A [[Partnerships]] |
| + | |||
| + | :49 B [[Partnership Income: Attribution]] | ||
| + | |||
| + | |||
| + | :51 [[Collection of Tax from UK Representatives]] | ||
| + | |||
| + | |||
| + | :54 [[Loans from Non-Resident Companies]] | ||
| + | :65 [[Protected Trusts]] | ||
:69 [[Foreign Currency Issues]] | :69 [[Foreign Currency Issues]] | ||
Revision as of 06:51, 6 April 2021
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
- Other topics arising in this context, including tax avoidance, and disclosure and compliance
It is the online version of Taxation of Non-Residents and Foreign Domiciliaries by James Kessler QC.
Contents
Non-dom policy & avoidance
Domicile & residence
- 3 Domicile
- 11 Exit Taxes
Income Tax: Principles & remittance basis
- 19 Mixed Funds
Income by category
- 22 Performers
- 35 PAYE
IT: General
IT avoidance codes
Capital Gains Tax
- 59 Sub-Funds
Funds
- 66 Unit Trusts
Inheritance Tax
- 49 A Partnerships
- 88 IHT DTA: USA
- 95 ATED Taxes
- 102 Foreign Entities
- 103 Hybrid Entities
- 106 A Reporting and Compliance
- 107 Claims
- 109B Trust Registration
- 111 Penalties
- 112 Money Laundering
Appendices
2021/22 edition
This site is in the process of being updated with the text of the 2021/22 edition of Taxation of Non-residents and Foreign Domiciliaries A paper version of the 2021/22 edition will be available in June.
To access TFD online, you will need an online licence. To obtain this, go to the publishers website or email [email protected]
Licences for the 2020/21 edition will cease to be valid on 6th April.
If you are an academic or other non-tax practitioner who wants access for research purposes, contact James Kessler
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) To order copies of the book email the publishers or go to the publishers' website.
-
- You may purchase a single or multiple user licence: To obtain these contact the publishers.
- Without logging in, you can access:
- Chapter 1 Foreign Domicile: Tax Policy
- Chapter 2 Tax Avoidance.
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 for the current edition. Registration for an earlier edition will cease to be valid from 6th April.
Comments please
Users can also contribute to the text and if you can add anything, 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 Ross Birkbeck.
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 or other members of his chambers to advise. See How to instruct James Kessler QC.
Archive editions
There are archive editions for years since 2003/04. These will 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 Ross Birkbeck, 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 a Wiki on the lines of Wikipedia, but only registered users can edit the text.
