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Latest Offshore Structure To Reduce CGT
Revealed - QC approved scheme to avoid CGT on the sale of UK investment property whilst UK resident/domiciledRevealed - QC approved scheme to avoid CGT on the sale of UK investment property whilst UK resident/domiciled
In this article, exclusively for our Gold members, we explore how UK residents and domiciliaries can use a Cyprus offshore structure to potentially avoid UK CGT completely on the disposal of UK investment property whilst still living in the UK. . . . keep reading


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  • latest tax articles

    Investing tax efficiently for your children
    01/09/2010
    Investing tax efficiently for your children This is a popular topic with site members, and as Child Trust Funds will be withdrawn after January 2011 this has led to a number of e-mails asking for tax efficient options to invest for children. In this article we look at the options for investing tax efficiently for your children . . . keep reading
    Changes to tax relief for pensions following July consultation document
    30/08/2010
    Changes to tax relief for pensions following July consultation document The Government is consulting on a new approach to limiting tax relief for pension saving by reducing both the annual allowance and the lifetime allowance. In this article we look at the impact of the proposed changes . . . keep reading
    New HMRC approach to domicile enquiries for inheritance tax purposes
    27/08/2010
    New HMRC approach to domicile enquiries for inheritance tax purposes HMRC will usually only enquire into your domicile status where it is directly relevant in terms of an immediate UK tax liability. One of the key occasions where domicile is an issue, particularly for non residents, is on a transfer to an offshore trust. In this article we look at the impact of the recent change in HMRC guidance in this area . . . keep reading
    How non doms can have a tax-free overseas investment portfolio
    25/08/2010
    How non doms can have a tax-free overseas investment portfolio The new tax rules make it unattractive for many non-doms to claim the remittance basis, especially those who are subject to the £30,000 charge. However, it's still possible to have a sizeable overseas investment portfolio and pay little or no tax in the UK. In this article we look at how non doms can have a tax free overseas investment portfolio . . . keep reading
    Final round for Gaines Cooper
    23/08/2010
    Final round for Gaines Cooper Gaines Cooper has received permission to appeal to the Supreme Court. This article looks at the history of the Gaines Cooper decisions and consider the likely issues in the latest (and possibly final) instalment of the Gaines Cooper saga . . . keep reading
    Court of Appeal decision in Smallwood and Company Residence
    20/08/2010
    Court of Appeal decision in Smallwood and Company Residence The Smallwood decision is a useful reminder of the issues in establishing central and management control overseas in the context of an offshore company. In particular the confirmation that you need to look at (1) whether there has been a usurping of the Directors powers, and if not (ii) whether there is an external party that dictates decisions to the Directors is useful. This article looks at the facts and decision of the Smallwood case. . . . keep reading
    Is this the first step to Dividends being charged to NIC?
    18/08/2010
    Is this the first step to Dividends being charged to NIC? When looking at extracting cash from a company, one of the advantages of a dividend, as opposed to a salary/bonus arrangement is that dividends are not subject to NIC. This can save you NIC (at 11% or 1%) and can also save the company NIC (at 12.8%). In this recent case HMRC challenged this tax treatment of dividends and argued that they should be subject to NIC. . . . keep reading
    Using an offshore company for a UK property purchase and UK shadow directors
    18/08/2010
    Using an offshore company for a UK property purchase and UK shadow directors We're often asked about the UK tax implications of purchasing a UK property via an offshore company. It's well known that non doms have an advantage as this takes the value of the property out of the UK estate for UK inheritance tax purposes, however what are the other tax implications of using an offshore company for UK property? . . . keep reading
    UK corporation tax planning after you've left the UK
    16/08/2010
    UK corporation tax planning after you've left the UK If you trade via a UK company, the general rule is that it would be subject to UK corporation tax even if the controlling directors or shareholders were non UK resident. However as a non resident individual you may be looking at options to reduce the UK corporation tax charge. In this article we look at the UK tax planning options . . . keep reading
    Tax treatment of Franchise payments and receipts
    13/08/2010
    Tax treatment of Franchise payments and receipts Many people are looking to invest in a franchise operation. In this article we look at the UK tax treatment of the various payments and receipts under a franchise agreement for both the Franchisee and the Franchisor . . . keep reading
    Tax Planning after the new UK-Hong Kong Tax Treaty
    11/08/2010
    Tax Planning after the new UK-Hong Kong Tax Treaty Until now there has been no tax treaty between the UK and Hong Kong. On 21 June 2010 a treaty was signed which should be in force from April 2011. In this article we summarise the key provisions of the new tax treaty and the tax planning opportunities arising from this . . . keep reading
    Review of HMRC draft guidance on company non residence
    09/08/2010
    Review of HMRC draft guidance on company non residence One of the key issues in using an offshore company is ensuring it is classed as non UK resident for tax purposes. This will be determined by where the central management and control of the business is carried out. Establishing where the management and control is carried out can be difficult to ascertain. HMRC have recently published some draft guidance on when they will and won't argue an offshore company is UK resident. In this article we provide a brief overview of the impact of this guidance. . . . keep reading
    Revealed - QC approved scheme to avoid CGT on the sale of UK investment property whilst UK resident/domiciled
    Revealed - QC approved scheme to avoid CGT on the sale of UK investment property whilst UK resident/domiciled In this article, exclusively for our Gold members, we explore how UK residents and domiciliaries can use a Cyprus offshore structure to potentially avoid UK CGT completely on the disposal of UK investment property whilst still living in the UK. . . . keep reading
    CGT changes make EIS investments less attractive
    04/08/2010
    CGT changes make EIS investments less attractive One of the downsides of the CGT changes in the recent Emergency Budget is that EIS investments will be less attractive. In this article we look at precisely why the new CGT changes make EIS investments less attractive . . . keep reading
    Changes to the tax treatment of loan notes on the sale of a company after June 2010
    02/08/2010
    Changes to the tax treatment of loan notes on the sale of a company after June 2010 The Emergency Budget in June 2010 made a number of changes to the tax treatment of loan notes after 22 June 2010. In this article we look at the impact of the capital gains tax changes on the sale of company shares in exchange for loan notes both before and after 23 June 2010 . . . keep reading
    Changes to tax relief on pension contributions following the Emergency Budget
    30/07/2010
    Changes to tax relief on pension contributions following the Emergency Budget The Emergency Budget brought major changes in a number of areas. Some of the key changes are the proposals to how to restrict tax relief for high earners. In this article we look at tax relief under the current pension regime and the proposed changes . . . keep reading
    Changes to the UK's special tax rules for seafarers
    28/07/2010
    Changes to the UK's special tax rules for seafarers There are some proposed changes to the tax treatment of seafarers. In this article we'll summarise the current tax treatment as well as look at the potential changes . . . keep reading
    Tax planning when investing in UK property
    26/07/2010
    Tax planning when investing in UK property We're often asked for tax structure where a UK non-resident and non-domiciled individual wishes to purchase a UK property. In this article we look at some of the tax planning issues and opportunities available . . . keep reading
    When to opt for an asset or share deal after the CGT changes from 23 June 2010
    23/07/2010
    When to opt for an asset or share deal after the CGT changes from 23 June 2010 When you're selling your company, there are two broad options. You could either structure the deal as a share deal or an asset deal. If you sell the shares, then the capital gain will arise on you (ie 10%, 18% or 28%). If you opt for an asset deal the company doesn't pay capital gains tax (which would only usually apply to individuals, trusts and executors). Instead it pays corporation tax on any capital gains. The tax rate will be its marginal rate of tax. In this article we look at precisely when it is attractive in tax terms to opt for a share or asset deal . . . keep reading
    2010 Non-residence checklist
    21/07/2010
    2010 Non-residence checklist If you're planning on leaving the UK and establishing non-residence it's essential that you take account of the tax implications and numerous tax planning opportunities available to you. In this checklist we run through around 25 key points that you should be considering . . . keep reading
    Pre-sale dividends after 22 June 2010 to reduce CGT?
    19/07/2010
    Pre-sale dividends after 22 June 2010 to reduce CGT? A pre-sale dividend used to be a very popular method of minimising tax on the eventual disposal of a company, however its use diminished with the reduction in the rate of CGT to 18% and where shares qualified for Entrepreneurs Relief.In this article we look at how the CGT changes announced from June 2010 impact on the use of a pre-sale dividend to reduce tax on disposal of a company . . . keep reading
    The new CGT transitional rules for non-residents and non-doms
    The new CGT transitional rules for non-residents and non-doms As we all know the maximum CGT rate has increased substantially for disposals after 22 June 2010. However, the recent Finance Bill has produced some useful clarifications on the transitional rules that will apply, in particular when disposals are treated as arising before or after 23 June 2010.In this article we look at how the new rules impact on non-residents and non-doms . . . keep reading
    Latest case on non residence (June 2010) and form P86
    14/07/2010
    Latest case on non residence (June 2010) and form P86 The latest case on non residence came before the First Tier Tribunal in June 2010. It concerned an individual working abroad and whether they were UK resident or not. Although it doesn't add much to the law relating to non residence, it's nevertheless well worth considering . . . keep reading
    A review of the new CGT provisions in the 2010 Finance Bill
    12/07/2010
    A review of the new CGT provisions in the 2010 Finance Bill The Emergency Budget on 22 June 2010 made some substantial changes to the capital gains tax regime. The Finance (No 2) Bill is going through Parliament and we thought it would be a good opportunity to have a look at the new legislation and see what it throws up. . . . keep reading
    Using a company to reduce taxes after the Emergency Budget
    09/07/2010
    Using a company to reduce taxes after the Emergency Budget There have been numerous changes to corporation tax rates and income tax and national insurance rates in recent years. The latest changes have been made in the recent Emergency Budget. However, just how will they effect your decision as to whether to use a company for your trade? . . . keep reading
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