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Briefing Notes

Reforms to the taxation of non-domiciles: further consultation

Introduction On 18 August 2016, HM Treasury published a further consultation on reforms to the taxation of non-UK domiciled individuals (“non-doms”). The changes are to take effect from 6 April 2017 and this note outlines the new deemed UK domicile rules and other proposals to charge inheritance tax (IHT) on UK residential property. The consultation […]

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2015 Summer Budget: Important Announcements For International Individuals

Non-domiciled tax status The government has announced that it will abolish permanent non-domicile tax status by changing the deemed domicile rules so that individuals who are UK resident cannot benefit from non UK domicile (“non-dom”) status indefinitely for tax purposes. Current rules As it stands, non-dom individuals pay Inheritance Tax (“IHT”) only on their UK […]

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Inheritance Tax Changes – Summer Budget 2015

The much heralded changes to Inheritance Tax are not as beneficial as they first appear. Lurking  in the small print behind the headline grabbing tax-free allowance of £1,000,000 for married couplesis the staggering of the new “residence nil rate band.” The effect of this is that although the new residence nil rate band will be […]

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Residential Property Tax Update

SUMMARY It is important for any individual or company to consider the tax implications in advance of the acquisition or disposal of residential property. The law in this area has been subject to recent changes, some of the most significant of which are discussed below. STAMP DUTY LAND TAX CHANGES Residential property acquired on or […]

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Accelerated Payment Notices From HMRC

The debate on the lawfulness of tax avoidance led to the introduction of Accelerated Payment Notices (APNs) in July 2014. APNs are issued by the HMRC on taxpayers believed to be avoiding tax. They allow HMRC to demand payment of disputed tax connected with Disclosure of Tax Avoidance Schemes. Through the use of APNs, of […]

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FATCA – The Deadline For Trust Registration Is Looming

The Foreign Account Tax Compliance Act (FATCA) was introduced in the United States with the aim of combating tax evasion through the use of foreign accounts by their tax residents. Following the UK/US Inter Governmental Agreement (IGA) and section 222 of the Finance Act 2013 this now forms part of UK law. HMRC has subsequently published […]

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The Gardiner Family: A Case Of Negligence By HMRC?

The Gardiner family (husband, wife and son) had taken part in a failed tax avoidance scheme. HMRC contended that they were negligent for having filed tax returns based on the assumption that the scheme was effective, up to the point where the Court of Appeal decided it was not. On the issue of negligence the […]

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High Value Residential Property Held By Non-Natural Persons – Budget 2014

In the Budget 2014 the Government announced measures which extend the current Stamp Duty Land Tax (SDLT) and Annual Tax on Enveloped Dwellings charge (ATED) where properties are acquired/held by non-natural persons. Legislation effecting these charges will be contained in the Finance Bill 2014. In addition the Capital Gains Tax (CGT) charge on enveloped dwellings […]

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