All tax practitioners with personal clients for whom international tax matters are a consideration will gain huge benefit from the wealth of advice in this book.
Many UK individuals choose to live and work overseas for a period of months or years. The decision to do so invariably has important tax compliance and planning implications. In this detailed, technical volume, the author, herself a British expat, guides the professional adviser through all the relevant tax issues, including residence and domicile, double tax treaties, special CGT and other reporting requirements, foreign tax considerations, etc.
New for this edition:
- Full update throughout for the abolition of the remittance basis and the introduction of the new foreign income and gains (FIG) regime from 6 April 2025
- Update of Chapter 2 for the changes arising now that domicile is no longer being used for UK tax purposes from 6 April 2025
- Update of the A Taxpayer case regarding exceptional circumstances for the statutory residence test and the taxpayers appeal to the Court of Appeal and subsequent win
- Expansion of the discussion of the terms “subject to tax” and “liable to tax” for treaty purposes
- The Masters case, which considered the “subject to tax” principle and whether a SIPP funded from an occupational pension scheme retained a link with the earlier employment and thus was only taxable in Portugal under the double tax treaty
- The suspension of double tax treaties with Russia and Belarus from a UK tax perspective
- Consideration of the McCabe case highlighting key points when establishing a person’s permanent home and centre of vital interests for treaty purposes and the tie-breaker clause
- The requirement for agents to obtain a client’s signature digitally when applying for tax repayments
- The new globally mobile employee PAYE notifications process in respect of the operation of PAYE on employees where only part of their salary is subject to UK tax
- Revised criteria in respect of certain travel and subsistence expenses as a result of domicile no longer being relevant for UK tax
- Update for abolition of FHLs rules
- Further HMRC proposals re Making Tax Digital for income tax and the application of these rules to taxpayers with qualifying income between £20,000 and £30,000 from 6 April 2028, as well as updates with regard to foreign domiciles and any individual who has to declare details on the residence supplementary pages (SA109) of the self-assessment tax return
- CGT rates updated for non-residential property disposals – there now being no difference between residential property and other assets other than carried interest
- A note on the error in HMRC’s guidance NI38 between 17 November 2017 and 8 April 2019 in respect of voluntary Class 2 NIC payments and its consequences
- The section on inheritance tax has been fully revised for the above changes in domicile and the introduction of the concept of a long-term resident
- The Yaqoobi case in respect of an individual who mistakenly thought tax returns did not to be filed as a result of leaving the UK
- The Howarth case in which missing the final step of electronic submission of the tax return was held to be a reasonable excuse with regards to late submission penalties
- A section on the new foreign income and gains (FIG) rules and regime, which includes an explanation of overseas workdays relief that can now be claimed by British domiciles and the transitional rules for previous remittance basis users
- Update of UK double tax treaties in existence
- Updated tax and NIC rates and allowances
- Deadlines and penalties for volunteers under MTD
