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Briefing Notes

French tax: extension of the trust reporting obligations

A new law of 12 February 2020 has extended the scope of the trust reporting obligations in France, adding a further layer of complexity to the French legislation on overseas trusts. The reporting obligations are far reaching and the penalties for non-compliance are severe. Trustees of non-French trusts may be required to report the creation, […]

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French tax reminder: trust reporting obligations

The French trust reporting legislation targets all trusts with French connections, however remote. Failure to comply with the reporting obligations is heavily sanctioned. Trustees need to regularly review whether the trust includes French situs assets and whether the settlor and/or any beneficiaries are French residents. Reporting obligations Trustees are required to declare any creation, modification […]

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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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