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Investing tax efficiently for your children
01/09/2010
This is a popular topic with site members, and as Child Trust Funds will be withdrawn after January 2011 this has led to a number of e-mails asking for tax efficient options to invest for children.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
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New HMRC approach to domicile enquiries for inheritance tax purposes
27/08/2010
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
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How non doms can have a tax-free overseas investment portfolio
25/08/2010
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
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Final round for Gaines Cooper
23/08/2010
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
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Court of Appeal decision in Smallwood and Company Residence
20/08/2010
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
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Is this the first step to Dividends being charged to NIC?
18/08/2010
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
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UK corporation tax planning after you've left the UK
16/08/2010
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
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Tax Planning after the new UK-Hong Kong Tax Treaty
11/08/2010
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
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Review of HMRC draft guidance on company non residence
09/08/2010
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
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Tax planning when investing in UK property
26/07/2010
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
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When to opt for an asset or share deal after the CGT changes from 23 June 2010
23/07/2010
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
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2010 Non-residence checklist
21/07/2010
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
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Pre-sale dividends after 22 June 2010 to reduce CGT?
19/07/2010
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
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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
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Latest case on non residence (June 2010) and form P86
14/07/2010
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
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Using a company to reduce taxes after the Emergency Budget
09/07/2010
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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Here's what our members are saying ...
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Jerry Brown, Edinburgh
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