Practitioners Zone

Business Asset Disposal Relief now carries an 18% rate. Understand the lifetime limit, qualifying conditions and the difference between sale proceeds and taxable gains....keep reading

How the rules from April 2026 affect family businesses and farms, including spouse transfers, AIM shares and the questions to ask before making gifts....keep reading

Moving to the UK or recently returned? Check eligibility, the cost of losing allowances and why the four-year window needs planning....keep reading

In this article we look at the UK tax implications for non-residents investing in UK property after the 2024 Budget....keep reading

In the 2024 Autumn Budget it was announced that Non Dom status will be replaced from April 2025 with a new residence-based Inpatriate Regime. We look at how this will operate based on the latest Finance Bill....keep reading

The 2024 Autumn Budget included significant inheritance tax changes to the availability of APR and BPR from April 6, 2026. In this article we look at the potential impact of these changes on trusts holding agricultural or business property....keep reading

In the 2024 UK Autumn Budget, the Chancellor announced changes to the inheritance tax with amendments to Agricultural Property Relief and Business Property Relief. In this article we look at the impact of the changes as well as simple planning strategies....keep reading

Moving to the UK requires consideration of a number of tax issues. One key issue is the treatment of any foreign incorporated companies that are owned or controlled. In this article we look at the key issues....keep reading

In this Practitioner Zone report we look at the tax treatment of land pooling arrangements, and some of the options to structure land pooling transactions tax efficiently....keep reading

Obtaining a UK domicile of choice can have a significant impact on an individuals UK tax treatment (including income tax, CGT and inheritance tax). In this article we look at how obtaining British citizenship can interact with this....keep reading

In this article we look at some of the factors to consider when choosing between a family trust or a family investment company....keep reading

In this Practitioner's article, we look at a recent case of the First Tier Tribunal on IHT 'Double Trust' planning....keep reading

In this Practitioner Zone report we look at the tax implications of a distribution in specie of UK residential property from an overseas company...keep reading

In this article, we look at some of the issues to be considered for long-term UK residents looking to avoid establishing a UK domicile of choice, including the impact of a recent case....keep reading

In many cases, the transferable nil rate band prevents the need to create a discretionary trust on the death of the first spouse. However, this is not always the case. In this article, we look at the role of discretionary trusts and deeds of variation in 2023 IHT Planning....keep reading

Following a request from one of our members we've looked in detail in this article at the UK tax implications of trusts migrating overseas. Trust migration essentially means that a UK resident trust becomes non UK resident....keep reading

One of the often forgotten implications of a transfer to an offshore company is that this is a chargeable lifetime transfer ('CLT') for inheritance tax purposes. In this Practitioner Zone article we look at how the 20% IHT charge on a CLT to an offshore company could be reduced...keep reading

Tax planning for holiday homes doesn't just require an analysis of the inheritance tax implications, but consideration should also be given to income tax, capital gains tax and stamp duty land tax. All of these can be relevant. In this practitioner zone article we look at the key tax planning options...keep reading

In this article we look at the tax issues to consider on corporate share deals including key tax exemptions, reliefs and considerations for a tax efficient disposal....keep reading

Gifts can be a highly effective strategy to minimise inheritance tax, however, the timing of gifts can have a significant impact on the amount of the IHT reduction. In this article we look at the timing of gifts for IHT purposes....keep reading

In this Practitioner Zone report we look at the IHT loss relief for shares and how beneficiaries can take advantage of this to reduce the IHT on shares....keep reading

Following a members tax question we've looked at the tax position of non resident partners. This article looks at how non UK resident partners are taxed in the UK and how they could structure their affairs to reduce UK tax...keep reading

In this Practitioner Zone report we look at the IHT position on gifts from life interest trusts....keep reading

When someone mentions a 'trust' the usual reaction is to think of a separate trust entity that has trustees and owns and manages assets on behalf of beneficiaries. However this is not necessarily the case. This article looks at the use of a bare trust and how it can be advantageous in tax terms, particularly for using children's annual exemptions....keep reading

On the death of a shareholder the question of whether the continuing shareholders have sufficient funds to buy the deceased's shares can be a significant issue. In many cases, a suitably-drafted cross-option agreement, backed by an appropriate term assurance policy is the solution. This can be drafted on a stand-alone basis or can be included as a separate section in a shareholders' agreement.In this Practitioner Zone article we look at this in more detail....keep reading

In this Practitioner Zone report we look at some simple strategies for using trusts in UK tax planning...keep reading

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

In this Practitioner article we look at the use of Growth Shares to structure a tax efficient business exit....keep reading

One possibility to reduce tax on property trading is by using a trust. The general idea would be that you could save the 40% or 45% income tax charge you'd be subject to if you did the development in your own name by using a trust. The trust could be subject to income tax at the basic rate of 20%. There could therefore be a significant tax saving. Practitioner Zone report....keep reading

The reservation of benefit rules are a very common trap for families looking to transfer ownership of the family home. In this article we look at the scope and impact of the rules....keep reading

In this Practitioner Zone we look at making gifts to reduce your estate for IHT purposes out of surplus income...keep reading

Individuals moving to the UK who hold an interest in, or have other connections with a non-resident company should carefully consider the impact of their personal change in residence with the residence of the foreign company. In this article, we look at some of the key considerations....keep reading

In this members article we look at the changes to the CGT treatment of inter-spouse transfers from April 2023....keep reading

One of the key benefits of making gifts out of income is that they are not potentially exempt transfers for IHT purposes and therefore aren't subject to the 7 year survivorship period. In this article we look at the latest rules on when and how to make gifts out of income....keep reading

This article looks at some of the issues and potential pre-arrival tax planning opportunities for an individual moving to the UK....keep reading

In this article, we look at one of the key measures in the 2023 Spring Budget, to remove the Pension Lifetime Allowance....keep reading

In this article we look at some of the measures impacting on the tax treatment of real estate in the 2023 Spring Budget. |...keep reading

In this article, we look at some of the key business tax developments in this weeks Budget....keep reading

In this article we look at some of the key personal tax changes in yesterday's 2023 Spring Budget....keep reading

In this article we look at how family investment companies can be used to pass wealth on tax efficiently....keep reading

In this Practitioner Zone report we look at when and how to "bank" the inheritance tax reliefs to reduce IHT...keep reading

We looked in a previous article at the two main methods of how a UK company can 'migrate' from the UK. In this article we'll look in more detail at a migration by transferring the management & control of a company overseas....keep reading

In this article we look at pre and post-sale trust planning issues and opportunities....keep reading

In this Practitioner Zone report we look at how to set the level of charges between UK and offshore companies. We look at three key areas that are commonly recharged: management services, interest and transfers of IP or other products. We look each area and examine how to determine an arms length rate...keep reading

In this practitioner zone report we look at the extent to which trusts can be used to ringfence assets, including when they are (and aren't) effective....keep reading

Both family investment companies and trusts can be useful for inheritance tax planning. In this article we look at the different tax treatment of both entities and when they can be useful....keep reading

In this article we look at how to make a gift correctly for IHT purposes. If the proper procedure isn't followed the gift can be ineffective for IHT, and the asset will simply remain in your estate...keep reading

Share buy backs are a common exit strategy when a founder or shareholder of a business wishes to leave. However, the tax treatment can be complex. In this article we look at the tax issues to facilitate a tax efficient exit....keep reading

If you're considering gifting overseas cash to family members you should ensure that you carefully consider the UK tax implications. In this article we look at the income tax and inheritance implications for both UK domiciliaries and non UK domiciliaries...keep reading

In this article we look at the options for structuring a personal injury trust....keep reading

In this practitioner zone report we look at the tax treatment of a UK resident individual receiving dividend income from India, including the impact of the UK-India double tax treaty...keep reading

The CGT annual exemption for individuals reduces from £12,300 to £6,000 from 6 April 2023, and to £3,000 from 6 April 2024. In this article we look at the options available....keep reading

In this Practitioner Zone report, we look at the interaction between UK and Swiss inheritance tax for individuals who are UK resident/domiciled with Swiss property and Swiss residents with UK property, including the impact of the UK-Switzerland estate tax treaty...keep reading

In this Practitioner Zone report we look at the tax residence of foreign trust companies including relevant procedures and actions to have in place to ensure the non residence status...keep reading

In this Practitioners article, we look at the key situations where a trust can still be beneficial, both for tax planning and other purposes....keep reading

We've looked in previous articles at exactly what constitutes a remittance of overseas income or capital gains. In this article we look in detail at exactly when and how taxable remittances are made using UK and overseas credit cards...keep reading

It's well known that there are specific anti avoidance rules than can tax parents on income arising to a child where they made the original transfer. In this article we look at the tax treatment of non doms who make transfers to minor children and how the anti avoidance rules will apply to them....keep reading

Without careful planning, in certain cases the 7-year rule for IHT potentially exempt transfers (PETs) can become the 14-year rule. In this article we look at when this can occur....keep reading

If you're a non dom and have been taxed on the remittance basis, determining the tax treatment of any remittance of proceeds from your foreign capital gains is crucial. In this article we look at the tax treatment of proceeds and capital gains under the remittance basis...keep reading

I have a Uk Ltd company and the majority of my travel and subsistence expenses are reimbursed by my major client in Italy. What is the best way to show these reimbursements in order to avoid they add up to my total turnover and increase my tax? Thks...keep reading

When planning for inheritance tax, any payouts under a life insurance policy can be included in your estate for inheritance tax purposes unless you arrange for the policy to be held in trust. This article looks at the tax implications of using a flexible gift trust or a bare trust to hold an insurance policy...keep reading

When considering your UK ties, what you must avoid at all costs, if you have been resident in any of the last three years, is to trip three of the sufficient ties tests. If you do, there is a special deeming rule whereby days of presence (and not only nights) will be counted. This article looks at this in detail...keep reading

In this article we look at the tax implications, opportunities and pitfalls of a gift and leaseback arrangement for the family home....keep reading

If you buy and sell any form of financial asset the chances are you'll be taxed as an investor.However, there is another classification that some can consider - this is being taxed as a trader. This article looks at the implications of the different status for financial traders and UK tax planning opportunities...keep reading

In this Practitioner Zone report we look at a recent case that looked at the tax treatment of dividends declared but not paid....keep reading

Land pooling (where 2 parties separately own land and agree to pool the land, usually to obtain planning permission and sell at a significant profit) can be complex, particularly in terms of the tax treatment. In this article we look at some of the tax structuring options...keep reading

In this article we take a look at recent cases and their impact on the tax residence position of trustees....keep reading

LLPs are required to annually re-test whether their members are employees or self-employed. In this article we look at the tests to be applied....keep reading

If you're looking at providing services from abroad to customers in the UK, it would be beneficial to pay careful attention to the terms of any double tax treaty. In this article we look at how using double tax treaties can significantly reduce your UK tax liability...keep reading

Working internationally (whether that is on a foreign secondment or simply being based in a different jurisdiction to your employer) can give rise to a number of UK tax issues. In this article, we look at the key tax issues and suggested measures....keep reading

In this article, we look at a recent case that looked at when an interim dividend was treated as paid for tax purposes....keep reading

Unlike individuals, companies are subject to an exit charge on becoming non UK resident. This applies where a company ceases to be resident in the UK and the broad effect of it applying is to ensure that any assets owned by the company are treated as being sold and immediately reacquired. This will then crystallise a charge to corporation tax on the capital gain that arises in the company. This article looks at the application of the exit charge provisions and how they can be mitigated....keep reading

Holding companies are often used as a form of financial funnel. By having a company located in a suitable holding company jurisdiction hold the shares in a variety of companies, it's possible to ensure that the profits are funnelled into a low tax, or tax advantageous environment....keep reading

In this article we look at the treatment of bonus payments made to members of an LLP. Determining the nature of the payment and whether the payment is made to an employee is a key consideration as employers NIC is levied on the payment if it is made in an employer-employee relationship....keep reading

As remote working is becoming more and more popular we thought we'd look at how a tax treaty would impact on someone working on the tax position for someone operating remotely....keep reading

We've received a number of questions recently relating to the tax position of gifts of income or capital from non resident/non doms. In this article we look at when such gifts can be subject to UK tax....keep reading

Following a request from one of our Practitioner members, in this Practitioner report we look at the UK tax treatment of payments to directors, including non-executive directors where additional services are provided...keep reading

In this members article we look at the current state of play in the taxation of crypto assets for UK resident individuals, including the tax planning issues and opportunities available....keep reading

In this article we look at the recent Court of Appeal decision that held that business asset disposal relief (Entrepreneurs Relief at the time) was available as the qualifying period to hold shares before disposal did not apply to trusts....keep reading

For CGT purposes, determining the period of ownership where there is an off-plan property purchase (and therefore the amount of PPR relief) can be complex.  In this article we look at the key principles based on case-law....keep reading

In this book we look at a variety of tax planning strategies that arise from the terms of the UK's double tax treaties. This book is updated for the 2022 changes....keep reading

Last week, John Swinney delivered the Scottish Government Budget for 2023/24. In this article we look at some of the key highlights....keep reading

In this Practitioner Zone report we look at a recent decision of the first tier tribunal that looked at the treatment of interim dividends and what this means for taxpayers....keep reading

For many people the family home is the most valuable asset they have. As such protecting its value will be of key importance. In this tax guide we look at the key tax planning opportunities for the family home and private residences....keep reading

This brand new (December 2022) edition of our best selling offshore tax planning book tells you what you need to know to take advantage of offshore opportunities and slash your UK tax bill. It's a pretty comprehensive look at plenty of UK and offshore tax planning techniques including residence, domicile, emigration, using offshore companies and trusts, buying property overseas and much more....keep reading

Inheritance tax is a particularly nasty tax as it's a tax on your capital that you've accumulated from your after tax earnings. In this book we look at some of the top ways you can legally reduce your inheritance tax liability....keep reading

The R&D tax credit regime is highly attractive and can currently provide a tax credit of around 33% of the expenditure paid. However, there are some significant changes to the regime from April 2023....keep reading

In this article we look at a recent decision of the first-tier tribunal that held that payments under an indemnity are not a remittance....keep reading

In this Practitioner Zone article, we look at the tax implications of the Autumn Statement for entrepreneurs....keep reading

In this article, we look at the latest decision of the first-tier tribunal on mixed use property for SDLT purposes....keep reading

The Autumn Statement included a number of key tax changes from April 2023. With the end of the tax year fast approaching we've put together a tax checklist to maximise tax efficiency before the 2023 tax changes come into effect....keep reading

This book looks at a number of tax planning issues for company owners and considers both corporate and personal tax planning opportunities available. It is updated for the latest changes for 2022/2023....keep reading

In this Practitioner Zone report we look at a recent case on the determination of capital gains on a foreign property....keep reading

Scottish tenants could obtain a refund of some of the land & buildings transaction tax (LBTT) paid when a lease is ended. We look at when and how this can occur in this article....keep reading

Determining tax residence status for the 2021/2022 tax year requires a consideration of the statutory residence test. HMRC have issued specific clarifications for determining residence status for the 2021/2022 tax year....keep reading

In this article we take a look at how a recent court decision impacts on the tax deductibility of deal fees....keep reading

In this article we look at the Patent Box scheme and how small & medium sized companies can use this to reduce their corporation tax rate to 10% on qualifying profits....keep reading

Buy-To-Let ("BTL") landlords have to consider Income Tax, Capital Gains Tax, Inheritance Tax and Stamp Duty Land Tax on their property holdings. In this book we look at tax planning techniques that all BTL landlords can consider to reduce the amount of these taxes they pay....keep reading

The measures announced in last week's Autumn Statement will increase the 60% effective tax rate. In this article we look at why....keep reading

Use our International Tax Personal Assessment Tool to identify the latest 2022 tax residence requirements and income tax rates in over 120 jurisdictions...keep reading

In this foreign tax planning article we look at the Portuguese income tax treatment of digital nomads, including tax residency and permanent establishment issues, as well as beneficial tax regimes...keep reading

In this foreign tax report we look at the Brazilian controlled foreign company (CFC) rules and the potential tax benefits of using a foreign holding company established in a treaty jurisdiction...keep reading

In this report we look in detail at the personal tax system for individuals in Barbados. This includes residence, the scope of tax, tax rates and the taxable basis, including key deductions, as well as the treatment of dividends, interest, royalties and rent....keep reading

In this report we look at Australia's temporary residence scheme, including the qualifying conditions and the key tax planning benefits....keep reading

In this post we look at some of the income tax incentives for non-resident individuals moving to Austria....keep reading

In this report we look at the tax benefits and qualifying conditions for individuals working in Belgium under Belgium's special regime for foreign employees...keep reading

In this article we look at the special tax regime for persons on temporary assignment in Sweden in 2021, including the tax benefits available and qualifying conditions...keep reading

In this report we look at the tax aspects of using a Swiss or a foreign company as an acquisition vehicle for a Swiss asset or share deal...keep reading

Not usually at the top of the list when looking at tax efficient holding companies, but a Norwegian holding company can be attractive in a number of scenarios. In this Practitioner Zone report we look in detail at the tax treatment and benefits of a Norwegian holding company....keep reading

In this foreign tax planning article we look at the controlled foreign company rules in Spain. These rules can attribute income of foreign companies to Spanish resident shareholders even if the foreign company does not distribute the income....keep reading

In this foreign tax planning article we look at the US tax treatment of foreign companies with US income. In particular, the scope of nature of the US tax depending on the source of income...keep reading

Bermuda does not apply a corporate income tax to corporations, however, there are economic substance requirements that should be taken into account for Bermudian resident entities...keep reading

Although the Bahamas does not levy corporate income tax, it does have economic substance requirements for certain Bahamanian entities. In this report we look at the scope of these requirements....keep reading

Although there is no corporate income tax in the BVI, there are economic substance requirements for certain resident companies...keep reading

Although there are no corporate income taxes in the Cayman Islands, there are economic substance requirements, which apply to a number of companies incorporated or registered there. In this article we look in detail at the scope of these requirements...keep reading

In this Practitioner Zone report we look at the VAT issues arising from trading in Argentina, including when the non resident supplier is required to register, VAT withholding requirements and the treatment of digital services provided in Argentina. |Image1|...keep reading

In this Practitioner Zone report we look at the VAT implications of trading in Ecuador, in particular the requirement to register for VAT, VAT withholding requirements and the treatment of digital services provided in Ecuador...keep reading

Detailed analysis of the key tax individual tax regimes in Europe for 2021, including an analysis of the Netherlands, Spain, Portugal, Sweden, Austria, Greece, France, Italy and Switzerland...keep reading

In this foreign tax planning article we look at the beneficial tax regime for individuals employed in the Netherlands...keep reading

In this article for our foreign tax subscribers we look at the Portuguese non-habitual resident scheme which can provide significant reductions in Portuguese taxation...keep reading

In this Foreign Tax Article we look at the special tax regime for expats in France, which can result in a full or partial exemption from French income tax...keep reading

In this Practitioner Zone report we look at Spain's special tax regime for EU/EEA residents...keep reading

In this Practitioner Zone report we assess the operation of the Swiss lump tax regime, including the qualifying requirements, cantons it is still available in and the calculation of the income tax charge in 2021...keep reading

In this Practitioner Zone report we look at the low tax benefits offered to individuals resident in Singapore, in terms of income tax, CGT and the tax treatment of employment income, investment income, foreign source income and the benefits of the NOR scheme...keep reading

Exclusively for our foreign tax subscribers, in this report we look at the tax treatment of foreign companies trading in Germany...keep reading

In this foreign tax planning article we look at Australian withholding tax on payments to non-residents....keep reading

In this foreign tax article we provide a detailed tax analysis of Brazil, focusing on both corporate and personal tax issues...keep reading

In this foreign tax article we take a detailed look at the Norwegian controlled foreign company provisions which counteract tax planning by Norwegian residents using certain foreign companies...keep reading

Establishing the level of taxable base is crucial when looking at foreign jurisdictions in order to determine the amount of tax due. In this ITDS report we look at how to determine the taxable base for 39 European jurisdictions...keep reading

In this ITDS report we look at property tax in 39 European Jurisdictions...keep reading

In this ITDS report we look at the corporate tax residence requirements in 41 European Jurisdictions...keep reading

In this ITDS report we look at Spanish tax planning for non resident individuals...keep reading

In this foreign tax planning report we take a detailed look at the Italian fixed rate regime and how the provisions of Article 24- bis of the Italian tax code apply, including how to take advantage of this beneficial tax regime....keep reading

In this ITDS report we include a detailed analysis of the personal tax regime in 41 European jurisdictions...keep reading

In this foreign tax planning article we look at tax issues and tax planning opportunities for expats and Australian residents with UK assets...keep reading

This comprehensive report looks at the tax treatment of domestic and foreign dividends in 37 European Counties. This is for subscribers to the foreign tax service....keep reading

In this report for our foreign tax subscribers, we look at the expanding scope of the Cayman Tax...keep reading

Foreign trusts should carefully consider if distributing capital gains to Australian resident beneficiaries remains a tax effective option. In this ITDS report we look at recent changes to the Australian tax regime...keep reading

Recent changes to the interpretation of various provisions relating to Beneficial Owners in Tax Treaties can be advantagous for anyone investing in China. In this ITDS report we look at the issues...keep reading

In this ITDS report we look at the recent Panamanian company tax registration changes ans requirements...keep reading

The Italian Budget Law 2018 introduced, amendments to the tax regime concerning dividends from non-resident companies located in low-tax jurisdictions. In this ITDS report we look at the key tax changes...keep reading

Given the recent US tax reform, in this ITDS report we look at how these changes impact on the choice of corporate structure and which is the best choice going forward...keep reading

In this ITDS report we look at tax planning for professional/technical services in India and how they are taxed under domestic law as well as under tax treaties....keep reading

In this ITDS report we look at some of the changes from the 2018 French Finance Bill and how they impact on HNWI's...keep reading

Recent changes in Spain require Spanish non-listed companies to disclose their ultimate beneficial owners. We look at the implications in this article...keep reading

In this ITDS report we look at the foreign tax treatment of interest in the jurisdictions of the EU...keep reading

In this ITDS report we look at the proposed changes to the tax treatment of non doms in Malta...keep reading

In this ITDS article we look at plans of the Dutch government targeting the avoidance of tax by letterbox companies and broadening the corporate income tax base...keep reading

In this ITDS report we look at the changing tax treatment of bare trusts and similar arrangements in Australia...keep reading

In this book we look at a variety of tax planning strategies that arise from the terms of the UK's double tax treaties. This book is updated for the 2022 changes....keep reading

For many people the family home is the most valuable asset they have. As such protecting its value will be of key importance. In this tax guide we look at the key tax planning opportunities for the family home and private residences....keep reading

This brand new (December 2022) edition of our best selling offshore tax planning book tells you what you need to know to take advantage of offshore opportunities and slash your UK tax bill. It's a pretty comprehensive look at plenty of UK and offshore tax planning techniques including residence, domicile, emigration, using offshore companies and trusts, buying property overseas and much more....keep reading

Inheritance tax is a particularly nasty tax as it's a tax on your capital that you've accumulated from your after tax earnings. In this book we look at some of the top ways you can legally reduce your inheritance tax liability....keep reading

This book looks at a number of tax planning issues for company owners and considers both corporate and personal tax planning opportunities available. It is updated for the latest changes for 2022/2023....keep reading

Buy-To-Let ("BTL") landlords have to consider Income Tax, Capital Gains Tax, Inheritance Tax and Stamp Duty Land Tax on their property holdings. In this book we look at tax planning techniques that all BTL landlords can consider to reduce the amount of these taxes they pay....keep reading

This guide is essential reading for anyone providing digital or online supplies of goods and services. It looks at the international tax treatment from both an income tax/corporate perspective as well as VAT/GST....keep reading

The aim of this guide is to give context to the considerations for 99% of international tax planning scenarios. Without understanding the information contained here, you will find it very difficult to apply or structure any kind of tax planning to your international transactions/assets....keep reading

The Statutory Residence Test ("SRT") applies from April 2013 and aims to provide a comprehensive method of clearly establishing when an individual will (and won't) be UK resident. In this guide we provide detailed guidance as to how the new rules apply and the tax planning opportunities available....keep reading

This 175 page book provides a rare insight into the glamorous world of tax havens and is fully updated for the latest 2021/2022 changes. The first half contains fascinating information on 30 of the world's best tax havens -- from the exotic Cayman Islands, British Virgin Islands and Monaco, to less well-known but highly attractive tax havens like Cyprus, Italy, Spain, Sweden, Malta, the Netherlands and the Isle of Man. The second half of the book explores how big companies and the rich use tax havens and how, with proper planning, you too could legally enjoy some of these benefits. |Image1|...keep reading

In this guide we look at what an LLP is, how it is taxed, and when and how you can use LLP's to reduce your UK taxes. We cover planning for income tax, capital gains tax and inheritance tax. This guide is essential reading for anyone interested in using an LLP....keep reading

This guide contains detailed information on how offshore companies are taxed in 2021/2022and how (and when) you can use them to reduce your UK taxes....keep reading

This Practitioner Zone guide looks at the tax regime for non UK domiciliaries ("non doms") as from April 6, 2017 and looks at some of the tax planning opportunities. It is updated for the 2017 Finance Bill, 2017 Finance (No2) Bill and analyses the impact of these changes on non doms....keep reading

The Government announced in its Autumn Statement 2015 that 3% higher SDLT rates will apply to purchases of additional residences from 1 April 2016. In this Practitioner Zone guide we look at the current state of play and the key tax planning opportunities....keep reading

The tax treatment of dividends is changing from 6 April 2016. In this Practitioner Zone guide we look at the current as well as the new tax regime to identify key tax planning opportunities....keep reading

Owning investment properties via a company has a number of tax advantages and in many cases it can be preferable to owning personally. However, there have been a large number of tax changes that affect both property investors and company owners from April 2016 and April 2017 and further ongoing changes that apply from April 2020. In this guide we look at the nature of these changes and assess how they impact on the decision to use a company to hold UK investment property. This Practitioner Zone guide is updated for the 2015 Budget, July Summer Budget and 2015 Autumn Statement provisions....keep reading

For many years company ownership of UK residential property was preferred by foreign property investors, however recent changes have changed this. This guide looks at tax planning for anyone interest in "de-enveloping" a UK residential property from a company (frequently an offshore company)...keep reading

The tax regime as it applies to investors in options, CFD's, bonds and other financial investments can be complex. In this guide we look at the tax treatment of these investments in detail. We illustrate the key points and planning opportunities with numerous easy to understand examples. This guide is updated for the 2015 Budget and July Summer Budget provisions....keep reading

Significant changes to the tax treatment of interest expenses incurred by property investors are to be implemented from April 2017. In some cases these changes will lead to a significant increase in the tax liability on rental profits. This Practitioner Zone guide looks at these changes in detail....keep reading

This Practitioner Zone guide looks at the tax regime for non UK domiciliaries ("non doms") in 2016 and 2017 and looks at some of the tax planning opportunities. It is updated for the 2015 Budget and July 2015 Summer Budget changes and analyses the impact of these changes on non doms....keep reading

This book looks in detail at how you can reduce capital gains tax in 2015/2016. The CGT reliefs are one of the main ways that most people reduce CGT. We therefore look at all of the main reliefs in detail. There are lots of other CGT planning opportunities from using the humble annual exemption to the more exotic such as using offshore trusts. We cover all of these in this guide....keep reading

In this new book we look at tax planning for UK residential property, taking account of the tax changes over the past two years and all future changes arising from the 2015 Budget and Summer Budget. We look at tax planning on purchasing UK property, funding the purchase, disposing of property, Inheritance tax planning and other issues...keep reading

Buy To Let ("BTL") landlords have to consider Income tax, Capital gains tax, Inheritance tax and Stamp duty land tax on their property holdings. In this book we look at tax planning techniques that all BTL landlords can consider to reduce the amount of these taxes they pay....keep reading

This book looks at a number of tax planning issues for company owners and considers both corporate and personal tax planning opportunities available. It is updated for the latest changes for 2015/2016 and includes numerous new sections....keep reading

This brand new (June 2015) edition of our best selling offshore tax planning book tells you what you need to know to take advantage of offshore opportunities and slash your UK tax bill. It's a pretty comprehensive look at plenty of offshore tax planning techniques including residence, domicile, emigration, using offshore companies and trusts, buying property overseas and much more....keep reading

Over recent years there have been changes to the capital gains tax (CGT) treatment of UK residential property held by companies. Further changes are to be made from 2015 and 2016 which will have a massive impact on how non UK residents and many non UK domiciliaries will be taxed on holdings of UK residential property. In this guide we look at the current CGT position and examine how the changes will apply before looking at the key tax planning opportunities going forward....keep reading

Structures such as the "Double Irish" and the "Dutch Sandwich" have gained press attention due to being used by various multinational groups to reduce their effective tax rate. Although changes are being introduced to target these, they are still effective. We look at how these structures operate and how you can use them in 2015....keep reading

In this book we look in detail at precisely how offshore companies owning UK property are taxed, taking account of the tax changes in 2013 and 2014 as well as the planned changes in 2015 and 2016....keep reading

Royalties present particular and unique challenges when it comes to tax planning. Not only do many companies own intellectual property, writing and selling both printed books and e-books online is becoming more popular. In this guide we look at some of the key tax planning opportunities for individuals and companies receiving royalty income....keep reading

In many ways one of the simplest ways to reduce tax is to hold assets and split income with your spouse and children/grandchildren. However, whilst there are numerous tax benefits available there are also some nasty traps for the poorly advised. In this Gold and Practitioner Zone book we look at exactly when and how you can shelter assets from income tax, capital gains tax and inheritance tax including planning with other family members....keep reading

If you're receiving a severance package, ensuring that you qualify for all your available tax exemptions/reliefs is important. In this Gold and Practitioner Zone report we summarise how these will apply...keep reading

Using a UK company as an agent for an offshore Principal can be attractive for both tax and asset protection purposes.In this Gold and Practitioner Zone report we summarise how this will operate and how it should be structured....keep reading

In this Gold and Practitioner Zone book we look at some of the key offshore tax planning concepts and opportunities for 2014....keep reading

There are a number of complex anti avoidance rules that can apply where offshore, non-resident companies are used for UK tax planning. In this Gold and Practitioner Zone book we look at 15 of the main ways that offshore companies can still be used for UK tax planning purposes. We look at how the anti avoidance rules apply in various scenarios and assess how these will impact on the UK tax treatment....keep reading

There are a number of hoops to jump through in order to claim Entrepreneurs relief and reduce your rate of CGT to 10%. In particular you need to ensure that the assets sold are "qualifying assets". You also need to ensure you have owned them for the requisite period of time and that none of restrictions or anti avoidance rules apply. We look at all of this (and more) in this book....keep reading

Trusts offer a highly attractive way to pass wealth onto other family members in a tax efficient manner. In this book we look at when and how both UK and offshore trusts can be used to reduce UK income tax, capital gains tax and inheritance tax....keep reading

If you're trading via a website or are involved in other e-commerce activities there are a number of tax planning opportunities available. In this book we look at tax planning for all types of e-commerce businesses - from maximising deductions and deciding whether to use a company, to structuring international e-commerce tax efficiently....keep reading

The new Statutory Residence Test ("SRT") applies from April 2013 and aims to provide a comprehensive method of clearly establishing when an individual will (and won't) be UK resident. In this guide we provide detailed guidance as to how the new rules apply and the tax planning opportunities available....keep reading

If you are trading or are planning to trade or develop property, a key consideration will be reducing the amount of UK tax charged on the profits from the development. In this guide we look at how property developers are taxed as well as the key techniques they can use to reduce UK tax....keep reading

If you're working overseas either as a permanent move or under a short term secondment you should carefully consider the tax planning opportunities available to you. Many people look to go and work overseas. One of the key considerations will be achieving the tax advantages that go with working overseas. In this book we look in detail at the tax planning issues and opportunities that everyone should be considering when they move overseas....keep reading

Of increasing importance to property investors are overseas property developments. Investors looking to benefit from higher levels of capital growth often look overseas. This opens up even more tax planning opportunities as now there are two (or more) jurisdictions to consider, as opposed to one....keep reading

Although there are now a raft of anti avoidance rules that apply to all sorts of offshore planning, for the well advised there are still opportunities available.In this guide we look at some of the top offshore tax planning opportunities still available and how you can use them....keep reading

Non UK domiciliaries are in a privileged position when it comes to UK Inheritance tax planning. So long as they can retain their non UK domicile status they can avoid UK inheritance tax on their overseas estate. Of course it is not quite this simple and there are a lot of obstacles to them benefiting from these rules....keep reading

In this guide we look at exactly how an LLP is taxed, before looking at how you can use LLP's to reduce your UK taxes. We cover how LLP's can be used by individuals as well as companies for UK tax planning....keep reading

If you're interested in offshore tax planning involving UK companies there are plenty of opportunities available.In this guide for our Gold & Practitioner members we show you how and when you can use your UK company as part of an offshore tax planning strategy....keep reading

Telecommuting is one of the hot topics at the moment. You've probably read of people sitting on a beach in the Caribbean working from their laptop, or sitting on board their boat moored in Cyprus and working from their mobile phone? Well if you have, this shows you the possibilities that telecommuting can offer you. In short we're talking a complete change in lifestyle for most people. This guide will show you exactly how you could be doing this....keep reading

Many people enjoy going on their summer holidays as a tourist in a foreign country. How would you fancy extending this 'holiday' permanently?The basic principle is to exploit the residency rules in a number of countries so that you're not caught by any one country's tax net.In this guide for our Gold Members we look at how you can achieve this and the tax planning benefits and issues involved....keep reading

There are a lot of firms offering to create low cost offshore companies, but which jurisdiction should you choose? In this mini guide we look at how offshore companies can be used and some of the top places to base your offshore company....keep reading

If you're selling your business or company this is an essential read. The tax at stake could be significant and this 170 page book goes through in detail the tax planning opportunities available to you to enable you maximise your net disposal proceeds. It covers lots of issues from straightforward tax reliefs such as taper relief and rollover relief to more complex reconstructions, hive ups and share reorganisations....keep reading

By undertaking simple tax planning many people can significantly reduce the amount of tax they pay. In this guide we look at 34 top tax tips to reduce income tax, capital gains tax, inheritance tax and SDLT....keep reading

Tax Question: Good morning, Could you please advise? A person sells a property in June 2024,pays the CGT as requested on the gain. Say the CGT rate changes to a higher rate in 2024/25 then may there be more tax to be paid? Thank you...keep reading

 Tax Question Our company has surplus balance in our currency account. (US dollar)  due to a slowdown. We get a far better return on a fixed term if the funds are placed abroad for a fixed period of one year. However The funds have to be placed in a personal name with an overseas bank. Is it possible to place the deposit in  my personal name however on behalf of the company. The principal and interest will be transferred back to the company on maturity and reflect in the company accounts. The overseas bank is aware these are company funds and no tax will be charged abroad. We can make a private agreement, or even a trust deed from or solicitor or advise HMRC, which option you think is the best so they do not treat this as a loan given to the director....keep reading

Tax Question: Hi. This is a hypothetical situation where the Limited Company (Subsidiary) is incorporated in UK, having no Permanent Establishment and no clients in UK. And the Holding Company is situated in Bulgaria. In this case which country the Subsidiary Company will be considered as Tax Resident and what are taxes that the Subsidiary will be liable to pay. Also what will be tax liability of the Holding Company if it receives Dividend, Interest and Capital Gains from the subsidiary....keep reading

Tax Question: Can a UK Limited Company (a Subsidiary of a Bulgarian Holding Company) having no permanent establishment and no clients in UK be non-resident in UK for tax purposes (Explain Why). If yes, is there any kind of income on which it has to pay taxes in UK only?...keep reading

Tax Question: I would like to ask about the idea of someone buying lots of shares in the stock market and holding them for a long time.  If these shares then double or more in price and would therefore result in a very large capital gain, would it be possible for the owner of the shares to move abroad to e.g., Dubai where there is no tax payable, and then sell the shares, and remain there for 5 years to become non resident before coming back to the UK?  Would that work in terms of not having to pay any capital gains tax on the gains?...keep reading

If a man is a non uk resident and non uk domicile, are his UK assets subject to IHT. If so - What are the IHT allowances - How much can he pass to his spouse without incurring IHT. Is it the total estate just like a UK resident, or is there a limit...keep reading

Tax Question: Hi Will there be SDLT to pay if properties are transferred into a trust based on market value. Assuming each value will be over the minimum thresholds? Thanks...keep reading

Tax Question: Hello. I have a question regarding inheritance tax. As a potential beneficiary to an estate who is not a resident of the UK, will I be subject to UK inheritance tax or the equivalent tax of the country where I reside?...keep reading

Tax Question: My company is cash rich I am the majority shareholder and I wish to purchase the other shareholders shares Whats the best way to do this?...keep reading

Question: Are there any UK tax implications for me (non-UK domicile non-UK resident) to send 11.000 pounds to daughter (non-dom but currently UK resident- since two years ago ) who is studying at university level in the UK at present ? Can I send the fund from my Jersey sterling account to her Isle of Man sterling account on which she can then write out a cheque ? Thank you...keep reading

Question: Having calculated goodwill being acquired by a limited company from a limited liability partnership, does the goodwill have to be reflected in the final balance sheet of the partnership accounts?...keep reading

Tax Question: dear wealth protection report i'm trying to understand what expenses i am allowed to claim for regarding company AGM meetings? if i plan to hold the company AGM in another location/city, book hotel accomodation, is the accomodation, food, travel expenses etc permissible as expenses? what would i have to do to ensure that i can prove that the purpose was for the AGM? kind regards...keep reading

Tax Question: My parents are UK doms and have a discretionary trust in the UK. Can this trust be moved to an offshore location? If so, will doing so provide any inheritance tax advantages? Thanks....keep reading

Tax Question: A franchise business has units in various shopping center. the Business is a UK Limited Company. Each unit is run by employees. The directors of the company manage each unit by visiting the shopping center and checking if everything is OK. Each directors are home based. Can he directors claim home to shopping center mileage?...keep reading

Tax Question: What is the best way of becoming NON domiciled of UK? I have been fiscally resident outside of the UK since 1995. Now fiscally resident in Portugal....keep reading

Tax Question: Hello - I have recently taken on an author who is UK resident but has also received book royalties from Germany. She has received such royalties from Germany over the past 4 years but the German publisher deducted withholding tax at 15.825% as the client did not provide any proof of UK residence. Had the client provided such proof then no German tax would have been deducted. I am in the process of preparing SA Tax Returns for the 4 years as she has not previously notified HMRC of her liability. Under the terms of the UK/German DTA - Article 12 - the royalties arising in Germany should only be taxed in the UK. Am I right in thinking that ,under any claim for Double Tax relief, the amount cannot exceed the overseas tax payable under the Treaty and that would be nil as no such German tax should be payable under Article 12? Is my client`s only recourse to approach the German Tax authorities to seek repayment of the tax by them? Thank you...keep reading

Tax Question: Purchasing an up and running exiting website. The Website is capitalised and will be depreciated. Can a company claim capital allowances and use the AIA for the year ? Or if the asset an Intangible asset [and amortised], what allowances can be claimed ? Thanks...keep reading

Tax Question: If a director and shareholder of a company incurs significant legal costs to exit that business to establish a similar trade / business in the same sector, are there any grounds for those costs being allowed in the new company as an allowable expense?...keep reading

Tax Question: My mother has put her house into 2 trusts: !. My fathers half, valued at £250K. Done by deed of variation, now in a discretionary will trust (beneficiaries= 3 children) 2.My mother's half valued at £325K in a family trust, same beneficiaries. She doesn't pay rent to the trusts therefore I assume they are in her taxable estate for IHT The house is now worth £1M. What will the tax status be when my mother dies? Can we assume full nil-rate band on house as she lives there or will the trusts be liable to CGT as beneficiaries of trusts are all home owners and higher rate tax payers. Thanks...keep reading

Tax Question: If I am a member of an LLP that purchases several classic cars for investment purposes but also to use. Are the costs of maintaining and running the vehicles available as losses to be offset against the members of the LLP's other income?...keep reading

Tax Question: Is the Dutch ZvW-contribution paid by a UK resident in fact "Dutch tax" and therefore potentially eligible for foreign tax credit relief? Or is this a non starter?...keep reading

Tax Question: Hi everyone, apologies if my question makes me appear a bit 'wet behind the ears' but is there: Any means of rewriting the will of a recently deceased person,using a 'Deed of Variation' to create a discretionary trust and escape a large inheritance tax on their estate? Many thanks for your time, A....keep reading

Tax Question: Box 7 of IHT 402. My father died in September and everything was left to mum in his Will. Mum died in August. Main asset was house - value £750,000 plus some cash so total about £800K. What value do I put in box 7 of IHT 402? I assume it would be £400,000 being Dad's half of the assets at death which were all in joint names. But no formal valuation of the Estate was done at the time as all left to mum. Or, should the value in box 7 be £nil as his estate was exempt from IHT by virtue of the spousal exemption? Your help please!!!! Thank you!!!...keep reading

Tax Question: Can non-dom own shares of isle of man co or BVI co or Malta co and not have deemed distribution...keep reading

Tax Question: I inherited my husband's estate and want to pass some or all of it to our children, grandchildren, and great-grandchildren. Can I do so without them being liable for inheritance tax? The legacy has been in my bank account for only two weeks and has never formed part of my estate....keep reading

Question: A mother X gifts her daughter Y her house. The daughter moves in with her even though the Y has another house (her main residence). X becomes disabled. X pays all the utility bills. Y pays the other expenses. Y owns the house outright. They live together for more than 15 years. X dies. Does the whole house or half the house belong to Y estate?...keep reading

Tax Question: We are going to sell our house and we are considering selling the garden at the side of us as a building plot. The entire garden [including that at the side]is less than half an acre will we have to pay CGT on the side garden land?...keep reading

Tax Question: H & W own a 'dormant' holding company in equal shares, this holding company owns a 25% share in a property investment company. Is there a tax efficient way of collapsing (removing) the holding company such that H & W own 25% share directly in the property investment company?...keep reading

Question: I understand that my domicile of origin is the nationality of my father (my parents were married when I appeared!). My father was born in Ireland pre-1949 (i.e. pre Republic and before the establishment of Northern Ireland). I was however born on UK territory where my father was living at the time. Is my domicile of origin Ireland or the UK?...keep reading

Tax Question: Hi Would a non-resident person be subject to income tax on any interest he charged on a loan to my UK Ltd company (interest would be rolled-up annually)? I am establishing a company to buy some land and build a house to let out but banks are not really interested in lending a startup company money on that basis. I have a non-resident family member who will lend the money but wants to charge a commercial rate of interest (I assume that could be high if no bank will do it) and doesn't want to pay UK tax. Is this possible? Thanks Yasman...keep reading

Tax Question: Hi, Is there a minimum period of time a donor of a business must survive for in order for the recipient to be free from any tax liability? thanks...keep reading

Tax Question: Hi, Co A is developing houses for rent and has been entirely funded by the directors. Upon completion, the company will apply for finance secured on the development so that it can repay the directors. Is it correct for the Co to claim tax relief for the interest payable on the loan? Thanks...keep reading

Tax Question: For the following part time business of (a) mini cab business (b)lending short term finance at market rates to his friends and associates. (c) rare stamp dealing. Are these iht qualifying assets for BPR?...keep reading

Tax Question: Sirs, Does a person who reside in England has to pay inheritance taxes on shares of foreign companies inherited from his father who is a foreigner not residing in UK knowing that there is no a tax treaty between the UK and the father's country. Many thanks...keep reading

Question: I have an inheritance tax question. Myself and my wife are both in our 80's. We have three children (both Sons). We provide financial assistance to each of them and want to ensure that the amounts we pay to them are exempt from inheritance tax. Our current annual income is 10 times the total "Gifts Out Of Income" to our 3 Sons. We provide financial help to each of them of around £5,000 per year. This includes the use of a credit card to pay for petrol and groceries, regular gifts of premium bonds and regulart cash transfers to a savings account. We want to make sure that we're OK to assume that these amounts will meet the criteria for the 'gifts out of income exemption' and that there will therefore be no inheritance tax charged?...keep reading

Tax Question: Is it possible to become non domiciled of the UK and maintain a home in the UK?...keep reading

Tax Question: When relying on a tiebreaker clause with a DTT, is it necessary to repeat the process each year?...keep reading

Tax Question: Can I set up an overseas company for the purpose of lending funds? Can I use these funds to either settle the existing mortgage or buy a new property for us to live? Is it also possible for that company to lend funds for BTL Property? What is the best jurisdiction to setup such a company and would you advise such shares to be bearer shares? Thanks,...keep reading

Tax Question: Is it possible to retain and carry forward tax losses accruing from a sole traders business when that business is incorporated? What impact if any is there on Incorporation relief provisions?...keep reading

Tax Question: The 7 year rule and gifting property to a limited company. What Taxes may the individual me liable for? And what is the best route to transfer property from the individual to a Ltd company?...keep reading

Tax Question: I am a Non Dom and pay tax on an arising basis. This tax year I made capital gains off shore and losses in the UK. May I offset one against the other? Thanks Louis...keep reading

Tax Question: If I become Non UK resident and live in France can I nevertheless make a Lifetime Property transfer of a UK property[ 7 years to clear ]? The French "gift " period is 15 years and is limited to 100000Euros....keep reading

Tax Question: When a UK Limited has capital increase or capital reduction, it would only take effect after it registers it with Companies House, right? Otherwise it would be invalid if the company shows such capital increase or decrease in it's accounts....keep reading

Tax Question: I understand it is relatively difficult to acquire a domicile of choice and thereby lose one's domicile of origin. Is it considered to be any easier to acquire a subsequent domicile of choice? For example, a UK domicile moves abroad and takes the steps necessary to establish a domicile of choice in the new country. Later, he/she moves to a third country, at which point his/her UK domicile is restored. Is the procedure for once again shedding the UK domicile and acquiring a domicile of choice in the third country any simpler/quicker than acquiring the original domicile of choice?...keep reading

Tax Question: What is the treatment for a property investment company that has Capital Allowances that go unused in the year of assessment? How can these be relieved?...keep reading

Tax Question: Can I gift cash to my children and then get them to loan it to me?...keep reading

Tax Question: I am not resident nor domiciled in the UK. I hold shares of UK companies in Jersey. Are these assets liable for UK Inheritance tax? Would putting these assets into an overseas company protect these assets from UK Inheritance Tax? Would the use of a Jersey trust assist in this case? Would the answers to these questions be different if I were not resident but was domiciled in the UK?...keep reading

Tax Question: Couple A have been non UK resident for 10 years. Their family home was a large country house and land in which their daughter and her family have continued to live. There is a derelict cottage on the property which couple A now intend to renovate and live in when they visit the UK. Couple A would like to gift the main house and land to their daughter and keep the cottage themselves. Can you advise the best way to achieve this....keep reading

Tax Question: if i gifted my business to my son in 2021 and my son continues in this business and i die in 2024. Does this gift (a) form a PET and (b) form part of my estate in 2024 for iht purposes?...keep reading

Tax Question: The basement of our house is a self-contained flat that we own on a separate lease. We are planning to take out a buy-to-let mortgage on the flat in order to raise money to convert it from a one bedroom to a two bedroom flat. (I've posted about this before.) In order to maximise the amount we can borrow against the flat, we plan to vary the lease to include the garden (it's currently restricted to the inside of the flat only, despite the fact that the flat has direct access onto the garden). Obviously in 'giving' the garden to the flat, we will increase the value of the flat and decrease the value of the house, which is our main residence. So our one concern is whether this could have capital gains tax implications. However, we plan to stay in this house long-term, and do not intend to sell the flat or the rest of the house. We figure that if we do have to sell up, we can always change the lease back again so that the main house gets a share in the garden (or gets the ...keep reading

Tax Question: I currently hold UK listed AIM shares and i'm currently resident in the UK. If I sell these shares whilst principally resident in Guernsey, would I pay any CGT on disposal of these shares?...keep reading

Tax Question Hello I'm trying to get information on the effect on Chinese withholding tax on interest paid to a foreign company. In particular, the effect of the Singapore and/or UK double tax treaties if paid to a company resident there? Thanks...keep reading

Tax Question: Dear wealthreport i have a company from which i do not take any salary or dividends. the earnings are retained by the company. if i wanted to take advantage of the childcare voucher scheme, could i take a salary for the amount of the childcare voucher - as a salary sacrifice - and still not take any other salary or dividend? thanks kind regards...keep reading

Tax Question: Hi Lady [A] has received through inheritance a 1/3 share of a freehold property [2/3 to other two siblings] The other 2 siblings wish to gift their shares to Lady A also. Lady A then intends to keep the property and eventually pass it down to her children in her will. No money is to be exchanged at any time. Could you kindly advise on the Inheritance tax and Capital gains tax implications in this scenario on each of the recipients of the gifted property ie Lady A and her siblings to Lady A's children. Thank you...keep reading

Tax Question: A DTA states "Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State." Does that mean that any Directors fees earned for board memberships in the country subject to the treaty are not taxable in the UK?...keep reading

I have a Uk Ltd company and the majority of my travel and subsistence expenses are reimbursed by my major client in Italy. What is the best way to show these reimbursements in order to avoid they add up to my total turnover and increase my tax? Thks...keep reading

Tax Question: Assuming property purchased with mortgage/loan from parents but after some years the parents decide to write the mortgage/loan off. What is the process to do this? 1) Can parents simply give a letter stating loan is written off? and what should the wording be? 2) Where should this letter be registered and within what period of time must it be registered? TIA...keep reading

Tax Question: Is it true that if a father (F) gifts the main residence £1m to a son (S) there would be zero CGT (due to PPR) and a PET for IHT which after 7 yrs will be zero, provided he also pay market rent for the accommodation (to avoid the reservation of benefit) until he ceases to use it eg. death or care home. If he dies before seven years does taper relief then apply?...keep reading

Tax Question: Hi What's the difference in tax calculations between transferring a property with no mortgage from a person's name to a limited company either a) as a gift with nil consideration vs b) as a normal transfer for market value consid...keep reading

Tax Question: Could you please help.. My mother who lives in England has proberty in England and in Italy, she has already made a will leaving her English property to my sisters and her Italian proterty to me as i live in Italy, we are having problems making a will for Italy, but thats not what i needed to know. I am worried about the inheritanza taxes..do l have to pay English taxes aswell as Italian taxes..and the same for my sisters do they pay taxes on the Italian inheritanze .? Thank you for any advice...keep reading

Tax Question: If I bought securities on margin, then are my capital gains reduced by that margin interest [i.e. are is the margin interest treated as a cost of trading the securities] or do I need to deduct the margin interest from the interest received in the year on my trading account?...keep reading

Tax Question: Hello, Is owning equity of a US-based company with a branch/permanent establishment in the UK considered to be foreign investment for UK tax purposes? Thanks!...keep reading

Tax Question: Is it possible to waive a proportion of a dividend. For example half the dividend that may become due in the following year on one share ? Is there a precedent in law for or against this ?...keep reading

Tax Question: My mother is 73 and Her assets are a flat worth 620k and cash of 190k. Father passed away around 35 years ago. We are 2 sisters what would be the best way forward to plan for IHT. Looking forward for your suggestions and tax implications....keep reading

Tax Question: I have a farm of about sixty acres which I have operated mainly with animals and arable for forty years and is excempt from IHT as agricultural property relief. As I am now approaching eighty years old and feeling the effects of those years of very long hours and hard work. I would like to branch more into holiday lets in shepherds huts and DIY horse livery. Would these operations effect the IHT status?...keep reading

Tax Question: Dear Sir./Madam. Can capital gains from the sale of digital currencies be claimed under the remittance tax basis, provided that a non-UK exchange was used for the sale and that the proceeds are kept in a non-UK bank account? The main question is about what qualifies as 'location of assets' in the case of digital currencies. Thank you....keep reading

Tax Question: Hi, I got a question about tax structure for SPV, company set up for investment purpose. If the company hold an investment property, and has a SIC code for property letting & management. The company then decides to invest into other assets such as shares. Assuming they are looking at purchasing shares and holding it for investment (not trading) Given that it's still an investment asset....does this change the structure of the company and how will tax be effected?...keep reading

Tax Question: I have 3 children. 2 of whom live in the family home and the 3rd lives abroad. They all own another rental property. I am looking sell 75% of the family home to them. Each will acquire 25% for £150k in separate transactions. How much stamp duty would each of them pay? Would they pay stamp duty based on £150k or £450k? Would those who live in the family home need to pay the additional rate?...keep reading

Tax Question: I'm writing a second edition of my book. If the book is published in the U.S., I have to pay a flat 30% withholding tax on all earnings. The publisher has asked if I would consider publishing via their UK office. As a non-resident British citizen, do you know how I would be taxed on a royalty advance and on any subsequent royalties that follow?...keep reading

Tax Question: For the count of 7of 9 years for the remittence charge, does a split year treatment count as one of the years of the 7 years. Specifically if it is the first year of the 7. Thanks....keep reading

Tax Question: I own (single owner) a UK ltd. company which owns property. Company is to be liquidated and the assets of the company, i.e. residential real estate (BTL), to be distributed in specie. Am I correct in assuming the company will have to pay the CGT on distribution, but I won't have to pay the SDLT, as assets distributed to me in specie by the liquidator?...keep reading

Tax Question: Is an IOM company liable to UK tax on its share of profits from a UK LLP?...keep reading

Tax Question: I am not UK tax resident. If I provide professional independent services FROM the UK to non-UK clients but the business has no fixed premises in the UK (just a virtual office address) will HMC tax my business profits? [I understand (I think) that under the DTT with my country of residence (Switzerland) I may be taxed if I offer services from a fixed base in Switzerland.¨]...keep reading

Tax Question: Hi Q. Off-shore Trust has made loan to Off-shore company who has in turn made loan to a UK resident company of which Mr A is a UK resident shareholder and beneficary of the off-shore trust. Settlor of the trust was non UK resident and non domicile. What would be the best way to give the above loan to the beneficary with least tax cost. Is there anything to watch out for re HMRC?...keep reading

Tax Question: Hi If a Singapore company receives dividends from a Russian company what would the withholding tax implications be please? It holds 40% of the Russian company.  Thanks  Jacz...keep reading

Tax Question: My father lives in New Zealand and has done so for the last 40 years, however he was in the UK, I live in the UK, would we have to pay IHT when we receive money from his NZ home....keep reading

Tax Question: My brother and I are shareholders and directors of a property, limited private company. It holds valuable property, mainly commercial, for long term investment. We are both over 65 years old and have always had good relations and we still do. He wants to retire and I want to carry on. He has 49% and I have 51% of shares. What do we do and how to minimise tax and legal complications? Could we- having obtained property valuations by an independent valuer-, divide up the properties in the same proportion by value as our share holdings, and then he would have his properties in a separate Company or limited Partnership and I have mine in a similar situation. Since there is no individual gain or loss in value to my brother or myself, there has been no disposals and so, hopefully, no CGT implications. Do you perhaps have a better solution?...keep reading

Tax Question: What is the most tax efficient way to buy a UK residential property for a UK minor?...keep reading

Tax Question: Hi, 1. The royalties are sold to a UK company by a Hong Kong company, with a deferred payment. The royalties are then leased to a Ukrainian company and the Ukrainian company makes regular payments in respect of the royalties to the UK company. The UK company uses funds so received to repay the Hong Kong company the deferred consideration outstanding on the royalties. Are there any restrictions which apply to the above in the UK? Does withholding tax apply to the payments which are made from the UK to Hong Kong? 2. Does any withholding tax apply in the UK if interest on a loan is paid from a company in Ukraine to a UK company and then paid on to a company in Hong Kong? 3. If dividends are declared from a Ukrainian company to a UK company and on to a Hong Kong company, does any withholding tax apply in the UK? 4. Is there a tax on dividends which are declared in Hong Kong in favor of a non Hong Kong resident shareholder? Many thanks...keep reading

Thanks for your answers and I have more questions after the arrows or comments after your answers >>> >>>>Home in the UK? What does a home in the UK mean exactly? I don't own any property. I do not have a rental contract in my name but I do have a place I can use to stay with my son, daughter and wife (she is only there some of the time) in Edinburgh. Is that a home? So is a 'home' mean owning a property? And I just have a 'place to live'? This is the sentence I am worried about: 'there is or was at least one period of 91 consecutive days when you had a home in the UK.' 1.You would certainly have a 3 year tie. >>>YES 2.You may well have a family tie >>>>YES 3.and an accommodation tie, depending on how long you visit them/stay in the UK. >>>>> YES: 'The individual will have an accommodation tie for a tax year if they have a place to live in the UK and: It is available to them for a continuous period of 91 days or more during that tax year, and they spend 1 or more nights there ...keep reading

Question: My older brother is fairly well off and has offered to buy some premium bonds in my name. How will this be treated for inheritance tax purposes. I know that premium bond winnings are free of income tax but what about inheritance tax? What is the position in the event of his death and also at the time of the gift to me?...keep reading

Tax Question: When looking at where assets are held for a EPT periodic charge calculation I am aware that for shares it is the registration of the shares that is important. If the UK shares are managed by an investment manager who is using an offshore nominee (rather than a trading company) account does this change where the assets are held....keep reading

Tax Question: Can you become UK tax resident WITHOUT meeting the current conditions for tax residency? For example, suppose as an "arriver" you only fulfill the single requirement of available accommodation and you never stay more than 100 days in the UK can you be "deemed" tax resident if you refer to yourself as UK resident for other purposes. And would it make any difference to the UK tax authorities if you were a "Tax Nomad"....keep reading

Question: I am a UK citizen and have lived here for over 7 years. Before that we lived in the US for over 20 years. I'm concerned about where my potential inheritance tax liabilities may lie (so I can the reduce it!). We have assets owned by us which are based in the US. This includes: - Bank accounts - US shares The income from the bank accounts is paid gross by the US and taxed in full in the UK. The US dividends though are subject to a 15% tax withholding in the U.S., but we then get a tax credit in the UK. What is the position for inheritance tax purposes under the Double Tax Treaty that exists between the U.S.A. and the UK?...keep reading

Tax Question: My wife is about to inherit some cash money and a share in property from her father in Jersey in the Channel Islands. This will be in the region of £500,000. Taxes will be paid on both aspects within Jersey but will she be liable for any inheritance tax in the UK...keep reading

Tax Question: One of my clients is a property development LLP (2 members).They bought a property for £210,000 to re-develop it into 7 apartments. the property still in their name and not the LLP company. They have already spent over £100,000 on the development. What are the advantages & disadvantages in transferring the property ownership to the LLP company. If they do make the transfer will they be able to claim the £210,000 and all the cost of the development from the company as a long-term loan. Are they entitle to any relief?...keep reading

Do you think that a gift of cash from an overseas (Jersey) bank account by a non UK domiciliary to UK beneficiaries would be exempt for UK inheritance tax purposes? If not would it be a PET? Note that this will be an electronic transfer of the cash (not a cheque). Does it make any difference?...keep reading

Tax Question: I am becoming a digital nomad and will be leaving the country before april this year. I have a UK company and would like to migrate that to malta for tax purposes. My company is a web application we sell on a subscription basis for thousands of customers worldwide. Our assets include our domains, custom software, customer base and brand. Regarding UK exit taxes, will there be CGT that I am personally liable for, or is it corporation tax due to asset sales? Or perhaps both? I was told by one person that the UK does not allow treaty migration so it would be asset sales (which I guess is corp tax.) Then another person told me that the UK absolutely did support treaty migration so I'm guessing that would be a share sale which is subject to CGT not UK corp tax? Hoping you can give me a definitive answer on this!...keep reading

Tax Question: Hi, Love the site! Finding it really useful. I am currently uk resident (and domiciled) but going to move to Malta next year with the view to being non uk resident and plan on being away from uk for more than 5 years. I am currently working for a uk company (on contract) via a limited company. There is a distinct possibility that when I tell them I'm leaving they will offer to let me work remotely. If not then I would not be working in Malta and living off my own funds. I understand the non residence test rules and would deliberately spend less than 16 days in uk for each of next 3 years to ensure I am non uk resident and would not return to uk (permanently) for at least 5 years (if at all). - If I work from malta (software development via remote VPN connection to client pcs) via my uk limited co, am I correct in understanding that I would pay uk corporation tax on the company profits but no other income tax in uk if I do not draw a salary? - my understanding is tha...keep reading

Tax Question: UK domiciled resident and sole shareholder of non-UK (but EU based) holding company. If UK resident sets up a UK ltd, can it be fully owned and financed by the EU holding company? Can any dividends of UK ltd post UK corporation tax be paid back to holding company? Are there any personal tax liabilities for UK resident shareholder of EU holding if no dividends are paid from the holding?...keep reading

Tax Question: Hi what tax is payable by a uk resident, who receives income from a non resident discretionary trust...keep reading

Tax Question: I got a job transfer to London from the midlands over ten years ago. I bought a flat jointly with my husband which was second home. I stayed in the flat for the entire time for the past ten years and my husband stayed there for about two years. He then moved back to our first home which is jointly owned. We are now selling the flat. Does principal private residence relief is applicable in this case? If applicable, what would be the duration of PPR for myself and for my husband....keep reading

Tax Question: In a small UK group of companies where the non trading Holding company is a company limited by guarantee with 3 member/directors, which owns 100% of a trading company with the same 3 people as directors, are there any circumstances in which the Holding company can distribute funds to the Members/Guarantors out of the retained profits of the trading company by way of a 'dividend' in the Holding company rather than as employment income in the trading company? Or any other way to get income out other than via salary? And/or is it possible for the Holding company to 'buy back' the beneficial interest of one of the Members for say a third of the company value and if so would that member get Entrepreneur relief as they have been a member for more than 2 years?...keep reading

Tax Question: I have a uk trading Ltd company with goodwill valued at £1.2m and tangible assets of 400k I wish to transfer the business to a newly formed UK Ltd company and retire from the business. The goodwill was purchased on incorporation in 2008 at a cost of £1m and CGT was paid by the vendor, ie me. I directly own all shares in both companies.If I transfer the goodwill direct to the new company will there be a taxable gain of £200k, or is this transfer exempt? If there is, can I avoid this by transferring shares in the new company from me to the old company befor transferring the assets? or by putting both comany's shares into a holding company?...keep reading

Tax Question: Non Resident CGT. Non resident coming back to UK. Purchased / acquire shares whilst non resident in EU country. If sells them whilst non resident then still not UK CGT event even if they come back to UK . I think the anti avoidance rules on sale of assets whilst "temporarily" non resident was in respect of pre - existing Uk assets from before you were non resident rather than assets acquired whilst non resident. So if pregnant with a gain best to sell them whilst non resident rather than wait and end up UK CGT on all. Is this correct? tks...keep reading

Tax Question: I understand that Canada does not have any form of IHT. However, should a resident of Canada dies certain assets are deemed to have been sold prior to death. If the deceased is a UK domicilary who would also have to consider such assets in the UK, do HMRC allow any deduction against the possible UK IHT liability to take into account any Canadian tax paid? Many thanks...keep reading

Tax Question: Hello, I am looking to setup a new business venture selling websites to small business in UK and USA I am a UK Citizen and resident and will want to work from Thailand have the following questions; 1. should i trade as a sole trader then switch to a UK Company and file Non Residence? 2. Should I just set up a offshore company and simply trade offshore? 3. Would it be a good idea to have freelance sales people in the UK? Please give me your thoughts thanks...keep reading

Tax Question: 1) Can you claim business property relief for inheritance tax purpose if your company runs a hotel business?it says land and buildings are excluded but hotel is a business....keep reading

Tax Question: Hello, my parents are looking at re doing their wills to save on inheritance tax. For the past 5 years i have been living in their home, covering my own expenses. am i correct in thinking that if they leave me this property in which we all live in their wills that it will be inheritance tax free? if not what will be the most tax efficient way of arranging my inheritance, as if the tax is too great i will have to move out anyway....keep reading

In this case study we look at tax planning for an IT contractor...keep reading

In this case study we look at tax planning for a UK resident holding US properties via an LLC...keep reading

In this case study we look at structuring UK and foreign businesses for a non dom including using offshore companies...keep reading

In this case study we look at when and how a specific UK trading company (in this case carrying out a vehicle trade) could use an offshore company by a UK trading company for UK tax planning...keep reading

In this case study we look at options for a US LLC trading in securities...keep reading

This is our recently updated Croatian tax guide. This looks at the corporate and personal tax regime in Croatia. For International Tax Developments Service subscribers...keep reading

This is our recently updated Indian tax guide. This looks at the corporate and personal tax regime in India. For Practitioner Zone subscribers...keep reading

This is our recently updated Pakistan tax guide. This looks at the corporate and personal tax regime in Pakistan. For International Tax Developments Service subscribers...keep reading

This is our recently updated Polish tax guide. This looks at the corporate and personal tax regime in Poland. For International Tax Developments Service subscribers...keep reading

This is our recently updated Russian tax guide. This looks at the corporate and personal tax regime in Russia. For International Tax Developments Service subscribers...keep reading

This is our recently updated Canadian tax guide. This looks at the corporate and personal tax regime in Canada. For International Tax Developments Service subscribers...keep reading

This is our recently updated Portuguese tax guide. This looks at the corporate and personal tax regime in Portugal. For International Tax Developments Service subscribers...keep reading

This is our recently updated Italy tax guide. This looks at the corporate and personal tax regime in Italy. For International Tax Developments Service subscribers...keep reading

This is our recently updated China tax guide. This looks at the corporate and personal tax regime in China. For International Tax Developments Service subscribers...keep reading

This is our recently updated Cyprus tax guide. This looks at the corporate and personal tax regime in Cyprus. For International Tax Developments Service subscribers...keep reading

This is our recently updated Thailand tax guide. This looks at the corporate and personal tax regime in Thailand. For International Tax Developments Service subscribers...keep reading

This is our recently updated Spain tax guide. This looks at the corporate and personal tax regime in Spain. For International Tax Developments Service subscribers...keep reading