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Non Resident and Offshore Tax Planning: Contents

Non Resident & Offshore Tax Planning

Contents

1. Introduction

2. Residence, Ordinary Residence & Domicile

2.1 Why do Residence & Domicile Matter?

2.2 Becoming Non-Resident

2.3 The Importance of 'Ordinary Residence'

2.4 Residence in a Nutshell

2.5 Why 'Domicile' is So Important

2.6 Watch Out for this Inheritance Tax Trap

3. How to Become Non-Resident

3.1 What You Stand to Gain

3.2 Convincing the Taxman You Are Non-Resident

3.3 How to Avoid Timing Traps

3.4 How the Taxman Decides Residence Status

4. How to Avoid UK Income Tax

4.1 Introduction

4.2 Rental Income

4.3 Interest & Royalties

4.4 Dividends

4.5 Pension Income

4.6 Employment Income

4.7 UK National Insurance

4.8 Pension Planning

4.9 Out of the Frying Pan and into the Fire

5. How to Avoid UK Capital Gains Tax

5.1 Introduction

5.2 Countries with Generous CGT Rules

5.3 Exceptions to the Five Year Rule

5.4 Traps to Avoid in the Year you Depart

5.5 Out of the Frying Pan and into the Fire

5.6 Postponing Disposals and Avoiding CGT

5.7 Avoiding CGT on Business Assets

5.8 Sale of a Former Home

5.9 Favourable Tax Jurisdictions

5.10 Using Enterprise Investment Schemes

5.11 Offshore Investments for UK Residents

6. How to Avoid Inheritance Tax

6.1 Introduction

6.2 How to Lose Your UK Domicile

6.3 How to Establish an Overseas Domicile

6.4 Retaining Your Domicile of Origin

7. The Advantages of Being Non-Domiciled

7.1 Non-UK Domiciliaries

7.2 Income Tax Planning

7.3 Using Split Contracts to Reduce Income Tax

7.4 Capital Gains Tax Planning

7.5 Making the Most of the Remittance Rules

7.6 Paying Less Tax on Investment Income

7.7 Incorporating Your Business to Avoid Capital Gains Tax

7.8 Buying Property Overseas

8. Working Overseas: A Powerful Tax Shelter

8.1 Introduction

8.2 Tax-Deductible Expenses

8.3 Tax-Free Termination Payments

8.4 Protecting Your Property Investments from the Taxman

9. Making Use of Double Tax Relief

9.1 Introduction

9.2 Credit Relief

9.3 Expense Relief

9.4 Underlying Tax

10. Tax Benefits of Offshore Trusts

10.1 Introduction

10.2 How Offshore Trusts Are Taxed

10.3 Capital Gains Tax Consequences

10.4 Inheritance Tax Consequences

10.5 Dangers for UK Domiciliaries

10.6 When an Offshore Trust Can Save You Tax

10.7 UK Resident but NOT UK Domiciled

10.8 Where Do You Set Up a Trust & How Much Does it Cost?

10.9 Using Trusts for Asset Protection

10.10 Keeping a Low Profile

11. Tax Benefits of Offshore Companies

11.1 Introduction

11.2 How the Taxman Spots Phony Offshore Management

11.3 Apportionment of Capital Gains

11.4 Benefits in Kind

11.5 Using a Non-resident Trust and Company

11.6 Using an Offshore Company & Trust: Non-UK Domiciliaries

11.7 Personal Service Companies

11.8 Transfer Pricing Rules

11.9 Types of Offshore Entity

11.10 Overseas Trading

11.11 UK Controlled Foreign Company (CFC) Rules

12. Investing in UK Property: A Case Study

12.1 Direct Ownership

12.2 Using a Trust to Own the Property

12.3 Using an Offshore Company

12.4 Conclusion

13. Becoming a Tax Nomad

14. Double Tax Treaties

14.1 How Double Tax Treaties Work

14.2 What a Typical DTT Looks Like

14.3 The UK-Isle of Man Double Tax Treaty

14.4 Using Double Tax Treaties to Save Tax

14.5 Treaty Relief

14.6 Considering a Move to Spain

15. Buying Property Abroad

15.1 Introduction

15.2 UK Resident/Ordinarily Resident and Domiciled

15.3 Non-Resident/Ordinarily Resident and Non-UK Domiciled

15.4 UK Resident/Ordinarily Resident and Non-UK Domiciled

15.5 Use of an Offshore Company/Trust

15.6 Using Mixed Residence Partnerships to Avoid CGT

15.7 What About Overseas Tax Implications?

15.8 Double Tax Relief (DTR)

15.9 Summary

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