Difference between revisions of "Main Page"
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# 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 | ||
− | # Other topics | + | # Other topics arising in this context, including tax avoidance, and disclosure and compliance |
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]. | 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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:6 [[Residence of Trustees]] | :6 [[Residence of Trustees]] | ||
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+ | :6A [[Corporate Residence]] | ||
:7 [[Treaty-Residence]] | :7 [[Treaty-Residence]] | ||
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:48 [[Intermediated Securities]] | :48 [[Intermediated Securities]] | ||
− | :49 | + | :49 A [[Partnerships]] |
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+ | :49 B [[Partnership Income: Attribution]] | ||
:50 [[Non-Resident Income Tax Relief]] | :50 [[Non-Resident Income Tax Relief]] | ||
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:73 [[Limitation on Benefits]] | :73 [[Limitation on Benefits]] | ||
− | :74 [[Foreign Tax | + | :74 [[Credit for Foreign Tax]] |
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+ | :New [[Non-discrimination]] | ||
:75 [[EU Law and UK Taxation]] | :75 [[EU Law and UK Taxation]] | ||
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:88 [[IHT DTA: USA]] | :88 [[IHT DTA: USA]] | ||
− | :89 [[Foreign IHT | + | :89 [[Credit for Foreign IHT]] |
:90 [[IHT Residential Property Code]] | :90 [[IHT Residential Property Code]] | ||
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:98 [[Who is the Settlor?]] | :98 [[Who is the Settlor?]] | ||
− | :99 [[ | + | :99 [[Multiple Settlors]] |
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+ | :99B [[Statutory Tax Indemnities]] | ||
:100 [[Situs of Assets for IHT]] | :100 [[Situs of Assets for IHT]] | ||
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:105 [[Permanent Establishment and Branch/Agency]] | :105 [[Permanent Establishment and Branch/Agency]] | ||
− | :106 [[Reporting and Compliance]] | + | :106 A [[Reporting and Compliance]] |
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+ | :106 B [[Tax Return Filing Position]] | ||
:107 [[Claims]] | :107 [[Claims]] | ||
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:108 [[Reporting and compliance: IHT]] | :108 [[Reporting and compliance: IHT]] | ||
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+ | :110 [[Reporting Offshore Trusts]] | ||
− | : | + | :110B [[International Movement of Capital: Reports]] |
− | :111 [[ | + | :111 [[Penalties]] |
:112 [[Money Laundering]] | :112 [[Money Laundering]] | ||
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:[[Appendix 3 Family Terminology]] | :[[Appendix 3 Family Terminology]] | ||
− | :[[Appendix 4 Consideration | + | :[[Appendix 4 Consideration/Arm's Length/Full Value]] |
:[[Appendix 5A Commercial/View to Profit]] | :[[Appendix 5A Commercial/View to Profit]] | ||
− | :[[Appendix 5B Receive/Entitled/Arise/ | + | :[[Appendix 5B Income Recognition: Receive/Entitled/Arise/Paid]] |
:[[Appendix 6 Associated Operations: IHT]] | :[[Appendix 6 Associated Operations: IHT]] | ||
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:[[Appendix 10 Parliamentarians]] | :[[Appendix 10 Parliamentarians]] | ||
− | :[[Appendix | + | :[[Appendix 11A Visiting Forces]] |
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+ | :[[Appendix 11B Students and Teachers]] | ||
:[[Appendix 12 How to Improve Residence and Domicile Taxation]] | :[[Appendix 12 How to Improve Residence and Domicile Taxation]] | ||
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:[[Appendix 15 The Wisdom of Parliament]] | :[[Appendix 15 The Wisdom of Parliament]] | ||
− | : | + | :[[Appendix 16 Participation Test]] |
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</div> | </div> | ||
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<big>'''2020/21 edition'''</big> | <big>'''2020/21 edition'''</big> | ||
− | This site contains the text of the | + | This site contains the text of the 2020/21 edition of ''Taxation of Non-residents and Foreign Domiciliaries'' with many post-publication [[Update | updates]]. A paper version of the book is also available. |
− | + | ||
− | + | ||
To access TFD online, you will need an online licence. To obtain this, go to | To access TFD online, you will need an online licence. To obtain this, go to | ||
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Licences for the 2019/20 edition are no longer valid. | Licences for the 2019/20 edition are no longer valid. | ||
− | If you are an academic who wants access for research purposes, [mailto:[email protected]?Subject=TFD%20online contact James Kessler] | + | If you are an academic or other non-tax practitioner who wants access for research purposes, [mailto:[email protected]?Subject=TFD%20online contact James Kessler] |
− | + | ||
<big>'''How to login'''</big> | <big>'''How to login'''</big> |
Revision as of 21:11, 3 March 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
- 3 Domicile
- 15 Mixed Funds
- 18 Performers
- 24 A Annual Payments
- 28 PAYE
- 47 Unit Trusts
- 49 A Partnerships
- 66 Sub-Funds
- 88 IHT DTA: USA
- 95 ATED Taxes
- 102 Foreign Entities
- 103 Hybrid Entities
- 106 A Reporting and Compliance
- 107 Claims
- 111 Penalties
- 112 Money Laundering
Appendices
2020/21 edition
This site contains the text of the 2020/21 edition of Taxation of Non-residents and Foreign Domiciliaries with many post-publication updates. A paper version of the book is also available.
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 2019/20 edition are no longer valid.
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 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 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.
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