It is March 2020 and two people are sitting at the departure gate at Heathrow waiting for their delayed flight to the Bahamas. They start a conversation and talk about why they are flying to this Caribbean island.
Person A, Mrs Exiteer, explains to Person B, that she had lived in the UK for a long time as a resident “non-dom,” but that changes to the tax rules for longer term … more
What is Changing?
India is tightening its residency provisions specifically to push ‘stateless’ persons (Indian nationals), who are not liable to tax in any other country, within the Indian tax net.
In addition, in order to become non-resident in India you will have to stay outside of India for at least 240 days per tax year and as detailed above, Indian citizens will also need to be liable to … more
IN618 What is the Impact of Brexit Likely to be for Turkish Nationals Benefiting from the Ankara Agreement
The Ankara Agreement enables Turkish nationals to enjoy a number of advantages in terms of emigration to EU countries.
The ‘Ankara Agreement’, as it is commonly referred to, was signed in 1963 between the Republic of Turkey and the European Economic Community (EEC). The Agreement was designed to encourage Turkey to become a Member State of the EEC by promoting economic relations. … more
Although the UK is no longer a member of the EU, a transition period is currently in place until at least 31 December 2020. During this period, most EU laws including EU free movement rules, continue to apply in the UK.
It remains to be seen how negotiations between the UK and the EU will affect the future relationship; however, the UK remains an attractive destination for … more
IN550 Visas Available to Non European Economic Area (EEA) Individuals Allowing Them to Work in the UK
This article summarises some of the UK immigration options available to individuals to conduct business and/or work in the UK. For information on the Tier 1 (Investor), the former Tier 1 (Entrepreneur), Start-up, and Innovator visa categories please see: Information Note 580
Short-Term Business Trips
It is possible to visit the UK and conduct business of a limited nature for up to … more
Individuals granted a Tier 1 (Entrepreneur) visa or Tier 1 (Investor) visa under the existing rules before/on 28 March 2019, as detailed below, are generally unaffected by new rules, effective from 29 March 2019. For more information, please refer to Dixcart Article: IN580 Reforms to UK Investor Visa Category and New Entrepreneur Visa Routes
Who Can Move to the UK?
EEA nationals and their … more
On 7 March 2019, the UK Home Secretary laid Statement of Changes to the UK Immigration Rules before Parliament, with these changes being introduced from 29 March 2019.
The changes primarily concern the closure of the Tier 1 (Graduate Entrepreneur) and Tier 1 (Entrepreneur) categories to new applicants, and these are replaced by the Start-up, and Innovator visa routes. The Tier 1 (Investor) … more
On 30 March 2019, the EUSS was fully implemented under UK domestic immigration rules, as a post-Brexit system. This allows EEA and Swiss citizens, and their family members, to continue to live and work in the UK – EEA is short for the European Economic Area comprising the EU, Iceland, Liechtenstein, and Norway.
Although the UK is no longer a member of the EU, a transition period is currently in … more
The Dixcart Group has more than 45 years of experience in assisting wealthy individuals and their families in matters of succession, estate planning and in the efficient administration of their affairs.
The Dixcart Group can assist with the formation and administration of trusts, foundations, private and managed trust structures and other family office services and is able to offer these … more
UK tax resident, non-domiciled, individuals who are claiming the remittance basis of taxation, do not pay UK tax on foreign income and gains, as long as these are not remitted to the UK.
It is, however, crucial to ensure that this tax benefit is properly planned for and claimed. For more information regarding formally claiming the remittance basis, please see Information Note 498. … more
The UK continues to be a favoured place for technology start-up companies, with 2019 investment growth, outpacing that of both China and the US.
According to the Government backed ‘Tech Nation Dealroom’, British technology start-ups raised $13.2 billion in 2019, an increase of 44% compared to 2018.
Eric Schmidt, who was the Chief Executive Chairman of Google for six years to 2017, stated; “ … more
With Brexit due to take place on 31 January 2020, UK immigration rules for EU citizens are likely to face further change. At the same time, the UK recognises the need to continue to attract talent from overseas and a number of measures introduced during 2019 indicate the direction that the UK is likely to be taking regarding immigration in 2020.
Since 28 January 2019, UK employers have … more
When Might You Consider Using a Will Trust?
Will Trusts can be used to protect property and assets within an estate.
They can be particularly appropriate to provide gifts and inheritance for children from previous relationships and to leave assets to a vulnerable or disabled person.
What are Other Potential Uses of Will Trusts?
Will Trusts can also be used for the following: … more
Recent changes in terms of global tax regulations and increasing international tax transparency are vital to consider when implementing strategies to preserve family wealth and family business ownership structures.
New global regulations include: Common Reporting Standard (‘CRS’), the US Foreign Accounting Tax Compliance Act (‘FATCA’), and several jurisdictions now operate … more
History – The ‘Substance Regime’
On 1st January 2019 the ”substance-based regime” was introduced into the Crown Dependencies (Guernsey, Jersey and the Isle of Man).
This has meant that since January 2019, companies engaging in “relevant activities” have had to demonstrate that they meet specific substance requirements, to avoid sanctions.
This ‘Order’ is in response to a comprehensive review, … more
IN604 UK Tax Considerations For Short Term Business Visitors To The UK And For Non-UK Resident Directors Of UK Companies
When individuals not resident in the UK are short term business visitors to the UK and/or are directors of UK companies, the individual’s UK tax position needs to be considered carefully. UK tax may be due, but there are a number of options that might reduce or negate the UK tax payable.
Short Term Business Visitors
Short-term business visitors are individuals who are not resident … more
Property in the UK can be owned by a company or by an individual and the method of ownership and the status of the company or individual involved will affect the tax treatment.
Tax on Rental Profit
Where an investment is made in UK commercial property in the name of a non-UK resident company and the company does not carry on a trade in the UK, basic rate income tax (currently 20%), is … more
Changes Being Introduced in April 2020
From April 2020, non-UK tax resident companies with income from UK property will no longer be charged UK income tax and will instead be subject to the UK’s corporation tax regime.
When the changes come into force, these companies will need to calculate their profits in accordance with corporation tax principles, which may represent a significant change … more
What is a Family Investment Company and Why Have One?
As anti-avoidance legislation aimed at trusts, is increasing, people are looking for alternatives to protect a family’s fortune. Whilst many people are happy to pass ownership to others they often wish to retain control.
Family investment companies (“FICs”) are being used increasingly by wealthy families to protect their family fortunes. … more
Dixcart Expertise in Relation to Wealth Structures
The Dixcart Group has over forty-five years’ experience in assisting clients to run and manage Family Offices.
We are very familiar with the issues facing families in this ever-changing international world and have extensive experience in providing trustee services in a number of jurisdictions.
We take time to establish and develop close … more
Liability to UK tax is broadly determined by the application of the concepts of "domicile" and "residence".
UK law relating to domicile is complex and differs from the laws of most other countries. Domicile is distinct from the concepts of nationality or residence. In essence, you are domiciled in the country where you consider you belong and where your real and permanent home is. … more
IN549(R) - КЛЮЧЕВЫЕ ПЕРСОНАЛЬНЫЕ ПОДОХОДНЫЕ НАЛОГИ И ПОТЕНЦИАЛЬНЫЕ ПРЕИМУЩЕСТВА ДЛЯ НЕ ДОМИЦИЛИРОВАННЫХ РЕЗИДЕНТОВ СОЕДИНЕННОГО КОРОЛЕВСТВА
Ряд стран предлагают режимы «налогообложения на основе перечисления, чтобы заинтересовать богатых людей в переезде из других стран, таких как Россия. Эти люди известны как «не домицилированные резиденты». Проще говоря, не домицилированный резидент - это человек, который не живет в своей стране «гражданской принадлежности».
Режим перечисления в Соединённом Королевстве является особенно привлек … more
A number of countries offer ‘remittance basis of taxation’ regimes to attract wealthy individuals to re-locate from other countries, such as Russia. These individuals are known as ‘non-doms’. Very simply expressed a non-dom is an individual not living in his/her country of ‘origin’.
The UK remittance regime is a particularly attractive example and although the rules have changed … more
The past few years have seen dramatic changes to the taxation of UK residential property for both UK and non-UK residents. Detailed below is a summary of the current position (as of June 2019).
It is important that existing structures (particularly those with foreign company ownership) are continually reviewed to ensure that the anticipated benefits of such structures remain … more
The UK continues to offer significant tax advantages for individuals who are resident but not domiciled in the UK. This is due to the availability of the remittance basis of taxation. The availability of the remittance basis for longer term residents was restricted from April 2017 and additional details are available on request.
Non-UK domiciliaries who are resident in the UK (whether on a short- … more
As families become increasingly international, with family members located in different countries, it is vital that appropriate wills are drafted and, subsequently, regularly reviewed and amended to reflect any variation in circumstances. Often the jurisdictions where assets are located and/or where family members reside will be subject to change.
Are wills only applicable to wealthy … more
The UK could be perceived to have one of the most punitive inheritance tax regimes in the world. Individuals pay a 40% rate on the value of their taxable estate above a tax free allowance of £325,000. In the case of a married couple this tax free allowance can be passed onto a surviving spouse, which means that, following their death, the estate will enjoy a £650,000 tax free allowance. … more
Many have asked “What are the implications caused by Brexit for the UK’s status as a premier jurisdiction for holding companies?”
In this Article we examine a number of the features that make a good holding company jurisdiction and consider the UK holding company in this context both pre and post Brexit.
Virtually all dividends received by a UK company, be they from the … more
On 8 September 2017, the second Finance Bill of 2017 was published. This confirmed that the previously announced policies, including amendments to the taxation of non-doms due to start on 6 April 2017, would be effective from that date.
In addition, further draft legislation, which will form part of a third Finance Bill, was published on 13 September 2017. This introduces new rules in relation … more
UK tax resident, non-domiciled, individuals who are taxed on the remittance basis, are not required to pay UK income tax and/or UK capital gains tax on foreign income and gains, as long as these are not remitted to the UK.
It is, however, crucial to ensure that this tax benefit is properly claimed. Failure to do so means that any planning undertaken by the individual might be ineffective and he/ … more
IN293 - UK Controlled Foreign Companies Rules - And Certain Exemptions That Can Reduce Or Remove The Obligation To Pay UK Tax
The UK updated its foreign company (“CFC”) rules on 1 January 2013. A number of exemptions apply that can reduce or remove the obligation to pay UK tax.
A CFC is a non-UK resident company controlled by persons in the UK. Typically a CFC is a foreign subsidiary of a UK group, although corporate control is not required for a company to be a CFC.
The rules, which are essentially anti- … more
Dixcart Business Centres offer extensive serviced office capacity and are ideal for companies establishing themselves in a new location. Dixcart Business Centres are located in Guernsey, the Isle of Man, Madeira (Portugal), Malta and the UK.
Business Centres can offer a productive work environment and a cost effective option for organisations with international interests wishing to operate from … more
There may be several reasons why individuals wishing to establish a company in the UK might consider the use of a Business Centre, providing not only serviced office capacity, but also substance. Business Centres can offer a productive work environment and a cost-effective option for organisations with international interests wishing to operate from a particular location.
A company establishing … more
WHY USE A UK COMPANY?
The UK Government has introduced many changes to make the UK tax system more competitive. This has led to the return of UK holding companies, the re-shoring of manufacturing and increased UK based research and development (R&D).
United Kingdom (UK) entities have a respectable international image and can be used tax efficiently for cross border trading and as international … more
What the UK Offers as a Tax Efficient Jurisdiction
One of the UK Government’s key ambitions has been to create the most competitive tax system in the G20. It has developed strategies to support, rather than hinder, growth and to boost investment.
Through the implementation of these strategies the Government is aiming to make the UK the most attractive location for corporate headquarters in … more
Major reforms regarding how UK tax resident, non-UK domiciliaries (“non-doms”) are taxed were introduced in April 2017.
The changes impact on individuals who have been tax resident in the UK for 15 years or more.
The Attractive Remittance Basis of Taxation will Continue for Many Non-UK Domiciliaries
The availability of the remittance basis of taxation for non-UK domiciled individuals who have … more
It is important that UK inheritance tax is taken into careful consideration, in particular by individuals who have assets in the UK. This Article examines how, with careful planning, some UK inheritance tax obligations can be mitigated for certain individuals.
What is UK Inheritance Tax?
UK inheritance tax (IHT) is a tax on money or assets held at death, and on some gifts made during a lifetime … more
It is possible for a company to be incorporated in one jurisdiction and to be resident in another. In certain circumstances this can generate tax efficiencies.
It is very important to always ensure that the company is properly managed and controlled from the jurisdiction in which it is resident.
The jurisdictions of Cyprus, Malta and the UK present a number of opportunities, as detailed below. … more