Many UK taxpayers in the last few months have surprisingly found in their mailbox a letter from HMRC about “Your Overseas Assets, Income or Gains” in which they were informed that HMRC has obtained information from overseas tax authorities about assets held by them in foreign jurisdictions on which they may have a UK tax […]

Business Investment Relief (BIR) is aimed at individuals who are residents but not domiciled or deemed domiciled in the UK who claim the remittance basis of taxation. The relief allows a remittance basis user to invest foreign income and gains in UK companies without triggering a tax charge. The rules governing the relief are found […]

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 […]

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 […]

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) […]