A new policy paper was recently published by HMRC with more details around the new non-dom tax rules effective from 6 April 2025. Below is an overview of the key points: End of Remittance Basis The government confirmed that the 2024/25 tax year will be the last year for which the remittance basis can be […]

The Italian government has announced a significant increase in the tax charge for individuals who transfer their tax residency to Italy, doubling the amount to €200,000. Under Italian law, similar to the UK, residents are taxed on their worldwide income. However, there is a special provision for those relocating to Italy, provided they have been […]

Background: in D’Angelin v Revenue and Customs Commissioners [2024] UKFTT 00462 (TC) Mr. Benoît D’Angelin, a UK resident but non-domiciled financier, invested £1.5 million of his foreign income into a newly founded UK company, D’Angelin and Co Ltd, anticipating that the investment would qualify for Business Investment Relief (BIR), rendering it non-taxable. The company provided […]

In the matter of Osmond and another v HMRC [2024] UKFTT 378 (TC), the First-tier Tribunal (FTT) adjudicated that taxpayers who executed a share buyback with the objective of crystallizing Enterprise Investment Scheme (EIS) relief from capital gains were deemed, as a matter of law, to have a main purpose of obtaining an income tax […]

On the 6th of March 2024, the Chancellor Jeremy Hunt announced the Spring Budget for the financial year 2023/2024. Although the priorities are still to reduce inflation below the 2% target, grow the economy and get debt falling, the Government confirmed that inflation has fallen from last year, growth has been more resilient than expected, […]