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UK Tax-News.com Coverage

- 24/05/2013 European Council Agrees To Anti-Evasion Initiatives
- 24/05/2013 Jersey, Guernsey Reply To Cameron Over Tax Info Exchange
- 22/05/2013 CBI President Calls For International Tax Rules To Be Fixed
- 22/05/2013 US Again Leads Global Fund Investor Experience Ranking
- 21/05/2013 Cameron Urges On Crown Dependencies Over Tax Info Exchange

More UK Tax News »

UK Tax Treaty Updates from TreatyPro

Treaty Update: United Kingdom - Various
29/4/2013
According to preliminary media reports, the UK's tax information exchange agreement with the former Netherlands Antilles, Curacao, St Maarten, Bonaire, Saba and St. Eustatius, will enter into force on May 1, 2013.

Treaty Update: Panama - United Kingdom
5/4/2013
Panama and the United Kingdom have agreed to the signing of a DTA in May 2013, Panama's ambassador to Britain, Ana Irene Delgado has announced.

Treaty Update: Spain - United Kingdom
27/3/2013
The United Kingdom and Spain have signed a new DTA, the Spanish Government announced on March 25, 2013.

More UK Tax Treaty Updates from TreatyPro »

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Related Information

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UK Features

- The UK's International Competitiveness - By Jason Gorringe, London
The UK's International Competitiveness: an analysis of double tax (onshore pooling), CFC rules and CGT treatment of corporate disposals; and how recent budgets have affected them.
- The One That Got Away - By Robert Lee, London
We examine the international repercussions for Britain of Gordon Brown's continuing failure to reform stamp duty legislation for share transactions.

UK Contributed Articles

- Offshore Companies Owning Uk Residential Property Need To Take Urgent Action, Contributed by Sovereign Group
- NEWSLETTER: SIPP/SSAS/QROPS2012- Updates and Reminders, Contributed by MW Pensions
- NEWSLETTER: SIPP/SSAS New rules 2011, Contributed by MW Pensions
- SIPPS: A Guide to Property Purchase and Lease, Contributed by MW Pensions
- NEWSLETTER: A Case for Corporate SIPPS?, Contributed by MW Pensions
- NEWSLETTER: SIPP Basic Rules 2011, Contributed by MW Pensions
- SIPP Property Syndicates: Clubbing together to buy larger properties, Contributed by MW Pensions
- SIPP/SSAS and the Case of the Disappearing Pension, Contributed by MW Pensions
- Residential Property: what is allowed: SIPP/SSAS/QROPS/QNUPS, Contributed by MW Pensions
- September 2011 Newsletter: HMRC Updates and reminders, Contributed by MW Pensions
- SIPPS Explained: Updated with new UK Rules, Contributed by MW Pensions
- Small Self-Administered Scheme (SSAS) or Self-Invested Personal Pension SIPP?, Contributed by MW Pensions
- Every Cloud has a Silver Lining - Exporting UK Trusts, Contributed by West Corporation Limited.
- July 2011 Newsletter: UK Pensions, Problems & Opportunities, Contributed by MW Pensions
- June 2011 Newsletter: UK Pension Changes = Opportunity, Contributed by MW Pensions

Topic: UK

tax releaf

i am a truck driver who spends between 15 and 20 days a month in europe and the rest of the time in the uk should i get more tax releaf then normal  

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Topic: UK

Retirement options

I am retired and draw a UK occupational pension of £200000pa. Because of income tax I receive less than £10k per month. We have assets totalling £3million, mainly in our family home which we need to dispose of.
What are my best for locating to a safe, tax friendly regime where HMRC will allow my pension to be paid free of UK tax and where there is no inheritance tax.
Advice please.  HMRC phobic

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Topic: UK

Becoming Non-Resident UK related taxation for remote consultancy

The situation detailed below is something which I have spent many hours discussing, considering and trying to resolve.

I would sincerely appreciate any advice offered as to whether my plans are sufficiently informed as to avoid repercussions from any authorities in the future:

Over the past few years I have been working on and off in a ‘consultancy’ role, primarily to a single UK company (developing new online sales markets) although also working for other firms in-line with IR35 regulations. Originally self-employed, I have been operating as a LTD company myself for the past 12 months and although barely present in the UK during this period, I have not registered as non-resident up to know.

I should point out that I have a very, very good relationship with the ownership of the trading company and a very flexible arrangement which has basically led to me retrospectively engineering my status from a tax point in recent years, in accordance with the success of our trading.

As I have been working outside the country successfully for most of the past year, and have spent more time outside the UK than inside over the past 5/6 years, I have decided to therefore become non-resident of the UK and will cease trading from my current UK based consultancy. I have reviewed the current regulations and the new 2013 statutory regulations regarding non-residency and will fall well within their guidelines. I’m well under 30 years old and therefore have no other business ties, no property and no family in the UK. Indeed I am considering to spend but 15 days in the UK for 2013-2014 and therefore leave no room for questioning that I am not UK resident. That said, I will certainly aim to present in the UK for around 40 days per year on average over the coming years, which falls well within the statutory requirements for my given circumstances.

Now. I am also to acquire a substantial shareholding of the UK trading company from in the near future.

My plan therefore is to setup an offshore company in the Isle of Man who I will work for. The IoMco will invoice the UK trading company for my consultancy services which will amount to 50% of annual profits. I have no need to draw down from this for personal funds in the near future.

I will notify the UK that I am taking up residence in a S.E.Asian country and I will not need to pay any income tax on dividends received from the offshore investment providing that they are not brought into said country in the same year they were earned. Indeed, I have no intentions to bring in any remotely significant amount of funds into said country and have a very simply standard of living. The dividends will paid into a personal bank account in the Isle of Man.

Although I realise the requirement to provide details of a new residency in order to demonstrate a clear break from the UK, I don’t intend to spend all of my time in ine country. It will however most likely be the place I spend the most time during a year. I understand that this requirement will also be less relevant with the new statutory residency test than it was before its introduction.

At this stage I am unsure of the best vehicle for purchasing the 50% stake of the UK trading company and quite how this will influence any perception of events in the eyes of the revenue is confusing me. It has been proposed that an Isle of Man trust would provide a certain level of anonymity but I’m not sure how relevant that is and indeed whether it is required at all. Other options would be to purchase the shares from my UK trading company but I feel that this is ‘too close to home’ in terms of maintaining ties to the UK. (I won’t become a director of the UK trading company).

I should point out here that I would certainly not rule out the possibility that I will return to live in the UK within the next 5 years. If it was possible to outline a minimum requirement of non-residency (years) for what I am trying to achieve then that would be useful. I believe at least 3 years would be advisable.

Now potential pitfalls that I can see to this plan is whether the revenue inspect the case to find that the earnings that are going offshore as ‘consultancy’ are in some way ‘UK sourced’. I fear that they might enquire as to where the work was done and whether I paid income tax to that jurisdiction.

Options for obtaining a work permit in said S.E.Asian country are not straight-forward. However I also realise that the UK authorities would need to exhaust considerable effort to follow the case up with said countries’ authorities.

In order to try to nullify any potential pitfalls here I have considered trying to gain a visa and work permit in order to work for my Isle of Man company out of S.E.Asian. The IoMco would then pay me a negligible salary which would be taxable in said country. I would then have an even stronger case for residency there and would be able to show the UK authorities that I had paid tax on my salary in said country (double tax treaty?). The dividends drawn down from the company would also be subject to local tax but as I would not be bringing them into the country, that tax would be null.

Further to this I could indeed sub-contract another portion of ‘work’ to an Irish friend to demonstrate that the work was indeed performed in another country and taxed there.

I don’t have any desires to try anything too clever or shady with this and would just like to have the situation setup and resolved so that I can get on with doing the work that earns the money. The figures involved are relatively substantial which is why I would like to get every aspect checked and confirmed to ensure that there’s no recourse should the revenue decide to investigate. However I do feel that my work, which I do almost entirely offshore, is worth 50% off the trading profits and therefore don’t feel that I’m doing anything untoward in sheltering that from UK tax if I’m not using any of the services for which that tax would provide.

Again, any advice offered in relation to this would be kindly appreciated.  

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Topic: UK

UK law linked to families/financial planning

I am a bilingual accountant in France, but am english. I am currently on a part time course studying financial planning and need to learn more about UK family law for my thesis. Can anyone give me the name of a, or several books on the subject for my research pls? I need to know the law on inheritance, mariage, divorce etc. linked with financial planniong. My thesis will be on the subject of the particularities of financial planning in France for residents or non residents of UK nationality.
I'll be coming to the UK soon so could get to a suitable book shop (any specialist book shops on lax in the UK?)
Many thanks for any help.  B. Dyason

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Topic: UK

Non Resident Status For Self Employed Working In China

Post Content

In a situation where a newly self employed person goes to work full time in China for a complete tax year, will HMRC award him non-resident status with regards to UK income tax for that tax year ? Also does it affect the decision if that person invoices a UK company or alternatively, a German company for his services?  

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Topic: UK

HMRC position in Administration/Liquidation

Change back to 1994 position where HMRC had first call in above cases - changed 6 April 2012? Any effective date and can it be respective in current cases.  Hugo

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Topic: UK

uk pension

if i am a non resident of the uk and my company pension is paid overseas do i have to pay uk income tax,if i am over 65.  david

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Topic: UK

renting

hi i have just purchased a leasehold flat in uk and have not paid tax yet the mortagage is 8000 and the service charge is 1500-2500. i get 12144 in rent .i am paye and earn 30-36k a year
what shall i do ?  

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Topic: UK

Manufacturing_Licensing and IP Assets

Dear Member,
A physical person based in Southern Euope is the Holder of Patents and Trademarks.
Such person intends to incorporate in an adequate Jurisdiction for conducting business at worldwide level.
Business will include essentially : 1) Out-licensing to third parties, therefore receiving payment of royalties 2) The production of several goods through contract manufacturers based in countries different from the jurisdiction of incorporation. The sale of such goods at worldwide level. The Owner of the IP needs to remain a "key figure" of the new Co. Such Co needs to be based in a reputable Jurisdiction as it needs to dialogue with public companies.
Possible solutions: A)"sell" the IP assets to a Co based in UK, CH, Delaware, Hong Kong, Singapore. and become employer B) Sell all the IP but retaining the license for southern europe... Alternatives appreciated. Regards, I.L.
through a series  

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Topic: UK

Maldives Islands

We are looking for a business partner investors to get through with us to tourism sector of Maldives.
To have a Resort Islands, Hotels,
Safari boats or hotel etc.
Plz contact me at seenmaldives@gmail.com  Seen Maldives

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Topic: UK

UK INCOME TAX THRESHOLDS (IN WEEKS) FOR NON RESIDENTS WORKING IN THE UK

Can you please tell me if there are any income tax thresholds in the uk for someone who wishes to work on sort term agency work through an offshore limited company in the UK before paying uk income tax, if so what is the threshold period allowed under uk tax laws.  

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