The Remittance Basis and Crypto Assets

The Remittance Basis of taxation is a generous relief on income and capital gains tax available to non-UK domiciliaries. When a claim is made, most categories of non-UK source income are not taxed unless remitted to the UK. The same principle applies to gains realized on the disposal of non-UK assets. Are crypto assets non-UK […]

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ATED - Annual Tax On Enveloped Dwellings

The annual tax on enveloped dwellings (ATED) was enacted by the Finance Act 2013. The tax was introduced to dissuade the acquisition of UK real estate through non-natural persons (so-called enveloping), mainly used to avoid the charge to Stamp Duty Land Tax or to leave the property out of one person’s estate for Inheritance Tax […]

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De-enveloping UK residential properties out of offshore companies

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) […]

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Tax Residence in the UK

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 […]

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