Not long ago it was common for non-UK domiciled individuals who were also not UK resident to purchase and hold residential real estate in the United Kingdom through offshore companies. The typical structure usually included an offshore trust on top of the offshore company. The reason was mainly to avoid stamp duty land tax (SDLT) […]
In the UK, with effect from 6 April 2013, the Statutory Residence Test (SRT) determines an individual’s residence status for the purposes of income tax and capital gains tax. The legislation can be found at Schedule 45 of the Finance Act 2013. Due to its mechanical approach, the SRT should objectively determine whether an individual […]
