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 [https://www.kessler.co.uk/taxation-of-foreign-domiciliaries/ ''Taxation of Non-Residents and Foreign Domiciliaries''] by [https://www.kessler.co.uk James Kessler QC]. |
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<div style="float: left; width: 33%"> | <div style="float: left; width: 33%"> | ||
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<big>'''Contents'''</big> | <big>'''Contents'''</big> | ||
− | [ | + | [[Update]] |
[[Introduction]] | [[Introduction]] | ||
− | :1 [[Foreign Domicile: Tax Policy | + | :1 [[Foreign Domicile: Tax Policy]] |
− | :2 [[ | + | :2 [[Tax Avoidance]] |
:3 [[Domicile]] | :3 [[Domicile]] | ||
− | :4 [[Deemed Domicile | + | :4 [[Deemed Domicile]] |
− | + | ||
− | + | ||
− | : | + | :5 [[Residence of Individuals]] |
− | : | + | :6 [[Residence of Trustees]] |
− | : | + | :7 [[Treaty-Residence]] |
− | : | + | :8 [[Exit Taxes]] |
− | : | + | :9 [[Split Years: Arrival and Departure]] |
− | : | + | :10 [[Temporary Non-residence]] |
− | : | + | :11 [[Source/Relevant Foreign Income]] |
:12 [[The Remittance Basis]] | :12 [[The Remittance Basis]] | ||
Line 48: | Line 44: | ||
:15 [[Mixed Funds]] | :15 [[Mixed Funds]] | ||
− | :16 [[Income | + | :16 [[Trading Income]] |
− | :17 [[Trading | + | :17 [[Trading in Land]] |
− | :18 [[ | + | :18 [[Performers]] |
:19 [[Property Income]] | :19 [[Property Income]] | ||
Line 70: | Line 66: | ||
:26 [[Employment Income]] | :26 [[Employment Income]] | ||
− | :27 [[Travel Expenses: Employment Income | + | :27 [[Travel Expenses: Employment Income]] |
:28 [[PAYE]] | :28 [[PAYE]] | ||
Line 82: | Line 78: | ||
:32 [[IIP Trusts: Income Tax]] | :32 [[IIP Trusts: Income Tax]] | ||
− | :33 [[Settlor-interested | + | :33 [[Settlor-interested Trust Code]] |
:34 [[Transfer of Assets Abroad: Introduction]] | :34 [[Transfer of Assets Abroad: Introduction]] | ||
Line 88: | Line 84: | ||
:35 [[Transfer of Assets Abroad: Transferors]] | :35 [[Transfer of Assets Abroad: Transferors]] | ||
− | :36 [[Transfer of Assets Abroad: | + | :36 [[Transfer of Assets Abroad: Benefits]] |
:37 [[Transfer of Assets Abroad: Relief from Overlapping Charges]] | :37 [[Transfer of Assets Abroad: Relief from Overlapping Charges]] | ||
Line 94: | Line 90: | ||
:38 [[Transfer of Assets Abroad: Motive Defence]] | :38 [[Transfer of Assets Abroad: Motive Defence]] | ||
− | :39 [[ | + | :39 [[Profit Fragmentation]] |
− | :40 [[ | + | :40 [[Life Policies and Contracts]] |
− | :41 [[Offshore | + | :41 [[Offshore Funds: Definition]] |
− | :42 [[ | + | :42 [[Offshore Income Gains]] |
− | :43 [[ | + | :43 [[Income from Offshore Funds]] |
− | :44 [[ | + | :44 [[Accrued Income Profits]] |
− | :45 [[ | + | :45 [[Deeply Discounted Securities]] |
− | :46 [[ | + | :46 [[Unit Trusts]] |
− | :47 [[ | + | :47 [[Intermediated Securities]] |
− | :48 [[ | + | :48 [[Partnerships]] |
− | :49 [[ | + | :49 [[Non-Residents Income Tax Relief]] |
− | :50 [[ | + | :50 [[Collection of Tax from UK Representatives]] |
− | :51 [[ | + | :51 [[Investment Manager Exemptions]] |
− | :52 [[ | + | :52 [[Investment Management Fees & Carried Interest]] |
− | :53 [[ | + | :53 [[Loans from Non-Resident Companies]] |
− | :54 | + | :54 [[Transactions in Securities]] |
− | :55 [[ | + | :55 [[Rates of Income Tax/CGT]] |
− | :56 [[ | + | :56 [[Personal Allowances]] |
− | :57 [[ | + | :57 [[National Insurance Contributions]] |
− | :58 [[ | + | :58 [[Chargeable Gains]] |
− | :59 [[ | + | :59 [[UK Property Held by Non-Residents]] |
− | :60 [[ | + | :60 [[Private Residence Relief]] |
− | :61 [[ | + | :61 [[Gains of Non-Resident Settlor-Interested Trusts: s.86]] |
− | :62 [[ | + | :62 [[Capital Payments from Non-Resident Trusts: s.87]] |
− | :63 [[ | + | :63 [[Borrowing by Non-Resident Trust: Sch 4B]] |
− | :64 [[ | + | :64 [[Protected Trusts]] |
− | :65 [[ | + | :65 [[Sub-Funds]] |
− | :66 [[ | + | :66 [[Gains of Non-Resident Companies]] |
− | :67 [[ | + | :67 [[Capital Losses]] |
− | :68 [[ | + | :68 [[Foreign Currency Issues]] |
− | :69 [[ | + | :69 [[Unremittable Assets]] |
− | :70 [[ | + | :70 [[Double Taxation Arrangements: Introduction]] |
− | :71 [[ | + | :71 [[DTA Anti-abuse Rules]] |
− | :72 [[ | + | :72 [[Foreign Tax Credit Relief]] |
− | :73 [[ | + | :73 [[EU Law and UK Taxation]] |
− | :74 [[ | + | :74 [[Excluded Property: Definition]] |
− | :75 [[ | + | :75 [[Excluded Property Exemptions]] |
− | :76 [[ | + | :76 [[Wills and IOVs]] |
− | :77 [[ | + | :77 [[Reservation of Benefit]] |
− | :78 [[ | + | :78 [[Inter-Trust Transfers: IHT]] |
− | :79 [[ | + | :79 [[IHT Deduction for Debts]] |
− | :80 [[ | + | :80 [[IHT Double Taxation Treaties: Introduction]] |
− | :81 [[ | + | :81 [[IHT DTAs: India, Pakistan, Italy, France]] |
− | :82 [[ | + | :82 [[IHT DTA: Netherlands]] |
− | :83 | + | :83 [[IHT DTA: Switzerland]] |
− | :84 [[ | + | :84 [[IHT DTA: USA]] |
− | :85 [[ | + | :85 [[Foreign IHT Credit Relief]] |
− | :86 [[ | + | :86 [[Non-Dom/Non-Resident Spouse]] |
− | :87 [[ | + | :87 [[Family Home and Chattels: Benefit in Kind Charges]] |
− | :88 [[ | + | :88 [[IHT Residential Property Code]] |
− | :89 [[ | + | :89 [[Pre-Owned Assets]] |
− | :90 [[ | + | :90 [[Joint Accounts]] |
− | :91 [[ | + | :91 [[ATED Taxes]] |
− | :92 [[ | + | :92 [[Estates of Deceased Persons: CGT]] |
− | :93 [[ | + | :93 [[Estates of Deceased Persons: Income Tax]] |
− | :94 [[ | + | :94 [[Who is the Settlor?]] |
− | :95 [[ | + | :95 [[Trusts with Two or More Settlors]] |
− | :96 [[ | + | :96 [[Situs of Assets for IHT]] |
− | :97 [[ | + | :97 [[Situs of Assets for CGT]] |
− | :98 [[ | + | :98 [[Foreign Entities]] |
− | :99 [[ | + | :99 [[Hybrid Entities]] |
+ | :100 [[Control Connected Close and Related Expressions]] | ||
− | :[[ | + | :101 [[Permanent Establishment and Branch/Agency]] |
− | :[[ | + | :102 [[Reporting and Compliance]] |
− | :[[ | + | :103 [[Claims]] |
− | :[[ | + | :104 [[Reporting and compliance: IHT]] |
− | :[[ | + | :105 [[Reporting Beneficial Owners]] |
− | :[[ | + | :106 [[Disclosure of Offshore Trusts]] |
− | :[[ | + | :107 [[Requirement to Correct]] |
− | :[[ | + | :108 [[Criminal Law and Professional Conduct]] |
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− | :[[Appendix 9: | + | |
+ | <big>'''Appendices'''</big> | ||
+ | |||
+ | :[[Appendix 1A: Words of Dispute]] | ||
+ | |||
+ | :[[Appendix 1: Common Legal Expressions]] | ||
+ | |||
+ | :[[Appendix 2: Family Terminology]] | ||
+ | |||
+ | :[[Appendix 3: Consideration, Arm's Length/Full Value]] | ||
+ | |||
+ | :[[Appendix 4: Associated Operations: IHT]] | ||
+ | |||
+ | :[[Appendix 5: Deeming Provisions]] | ||
+ | |||
+ | :[[Appendix 6: What Do We Mean by "Real"]] | ||
+ | |||
+ | :[[Appendix 7: Parliamentarians]] | ||
+ | |||
+ | :[[Appendix 8: Visiting Forces]] | ||
+ | |||
+ | :[[Appendix 9: How to Improve Residence and Domicile Taxation]] | ||
+ | |||
+ | :[[Appendix 10: Reform of Offshore Anti-avoidance Rules]] | ||
+ | |||
+ | :[[Appendix 11: UK Arrival or Departure: Tax Checklist]] | ||
+ | |||
+ | :[[Appendix 12: The Wisdom of Parliament]] | ||
+ | |||
</div> | </div> | ||
+ | |||
+ | <big>'''New 2019/20 edition now out'''</big> | ||
+ | |||
+ | The 2019/20 printed edition of ''Taxation of Non-residents and Foreign Domiciliaries'' is now out. The online edition contains the text of that edition with some subsequent [[Update | updates]]. | ||
<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) To order copies of the book [mailto:[email protected]?Subject=TFD%20enquiry email the publishers] or [http://khpplc.co.uk/ go to the publishers' website]. | |
− | + | You may purchase a single or multiple user licence: To obtain these [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]]; Chap 2 [[Tax Avoidance]]. | |
− | + | ||
− | + | 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>''' | + | <big>'''Comments please'''</big> |
− | Users can also [[contribute to the text | + | 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 [https://www.taxchambers.com/barrister/ross-birkbeck/ Ross Birkbeck]. |
<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> | ||
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To contact James Kessler QC [mailto:[email protected]?Subject=TFD%20online click here] | To contact James Kessler QC [mailto:[email protected]?Subject=TFD%20online click here] | ||
− | To contact | + | To contact Ross Birkbeck, who reviews online contributions, [mailto:rossbirkbeck@15oldsquare.co.uk?Subject=TFD%20contact%20moderator%20request click here] |
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 10:45, 19 July 2019
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
- 15 Mixed Funds
- 18 Performers
- 28 PAYE
- 46 Unit Trusts
- 48 Partnerships
- 65 Sub-Funds
- 84 IHT DTA: USA
- 91 ATED Taxes
- 103 Claims
Appendices
New 2019/20 edition now out
The 2019/20 printed edition of Taxation of Non-residents and Foreign Domiciliaries is now out. The online edition contains the text of that edition with some subsequent updates.
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: Chap 1 Foreign Domicile: Tax Policy; Chap 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 with the password for the current edition. Registration for an earlier edition is not valid.
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 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 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 in technical terms a Wiki on the lines of Wikipedia, but only registered users can edit the text.
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