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… Continue reading Update on New Non-Dom HMRC Policy Paper
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Italy doubles Tax Charge on Foreign Income and Gains to €200,000
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… Continue reading Italy doubles Tax Charge on Foreign Income and Gains to €200,000
Business Investment Relief Denied to Remittance Basis Taxpayer for Infringing Extraction of Value Rule
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… Continue reading Business Investment Relief Denied to Remittance Basis Taxpayer for Infringing Extraction of Value Rule
Main Purpose Test Met in Share Buyback Despite Absence of Actual Intent to Secure Income Tax Advantage
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… Continue reading Main Purpose Test Met in Share Buyback Despite Absence of Actual Intent to Secure Income Tax Advantage
Spring Budget 2024
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,… Continue reading Spring Budget 2024