Non Resident and Offshore Tax Planning
Contents
Chapter 1. Introduction
Chapter 2. Residence, Ordinary Residence & Domicile
- 2.1 Why do Residence & Domicile Matter?
- 2.2 Becoming Non-Resident
- 2.3 The Importance of 'Ordinary Residence'
- 2.4 Residence in a Nutshell
- 2.5 Why 'Domicile' is So Important
- 2.6 Watch Out for this Inheritance Tax Trap
Chapter 3. How to Become Non-Resident
- 3.1 What You Stand to Gain
- 3.2 Convincing the Taxman You Are Non-Resident
- 3.3 How to Avoid Timing Traps
- 3.4 How the Taxman Decides Residence Status
Chapter 4. How to Avoid UK Income Tax
- 4.1 Introduction
- 4.2 Rental Income
- 4.3 Interest & Royalties
- 4.4 Dividends
- 4.5 Pension Income
- 4.6 Employment Income
- 4.7 UK National Insurance
- 4.8 Pension Planning
- 4.9 Out of the Frying Pan and into the Fire
Chapter 5. How to Avoid UK Capital Gains Tax
- 5.1 Introduction
- 5.2 Countries with Generous CGT Rules
- 5.3 Exceptions to the Five Year Rule
- 5.4 Traps to Avoid in the Year you Depart
- 5.5 Out of the Frying Pan and into the Fire
- 5.6 Postponing Disposals and Avoiding CGT
- 5.7 Avoiding CGT on Business Assets
- 5.8 Sale of a Former Home
- 5.9 Favourable Tax Jurisdictions
- 5.10 Using Enterprise Investment Schemes
- 5.11 Offshore Investments for UK Residents
Chapter 6. How to Avoid Inheritance Tax
- 6.1 Introduction
- 6.2 How to Lose Your UK Domicile
- 6.3 How to Establish an Overseas Domicile
- 6.4 Retaining Your Domicile of Origin
Chapter 7. The Advantages of Being Non-Domiciled
- 7.1 Non-UK Domiciliaries
- 7.2 Income Tax Planning
- 7.3 Using Split Contracts to Reduce Income Tax
- 7.4 Capital Gains Tax Planning
- 7.5 Making the Most of the Remittance Rules
- 7.6 Paying Less Tax on Investment Income
- 7.7 Incorporating Your Business to Avoid Capital Gains Tax
- 7.8 Buying Property Overseas
Chapter 8. Working Overseas: A Powerful Tax Shelter
- 8.1 Introduction
- 8.2 Tax-Deductible Expenses
- 8.3 Tax-Free Termination Payments
- 8.4 Protecting Your Property Investments from the Taxman
Chapter 9. Making Use of Double Tax Relief
- 9.1 Introduction
- 9.2 Credit Relief
- 9.3 Expense Relief
- 9.4 Underlying Tax
Chapter 10. Tax Benefits of Offshore Trusts
- 10.1 Introduction
- 10.2 How Offshore Trusts Are Taxed
- 10.3 Capital Gains Tax Consequences
- 10.4 Inheritance Tax Consequences
- 10.5 Dangers for UK Domiciliaries
- 10.6 When an Offshore Trust Can Save You Tax
- 10.7 UK Resident but NOT UK Domiciled
- 10.8 Where Do You Set Up a Trust & How Much Does it Cost?
- 10.9 Using Trusts for Asset Protection
- 10.10 Keeping a Low Profile
Chapter 11. Tax Benefits of Offshore Companies
- 11.1 Introduction
- 11.2 How the Taxman Spots Phony Offshore Management
- 11.3 Apportionment of Capital Gains
- 11.4 Benefits in Kind
- 11.5 Using a Non-resident Trust and Company
- 11.6 Using an Offshore Company & Trust: Non-UK Domiciliaries
- 11.7 Personal Service Companies
- 11.8 Transfer Pricing Rules
- 11.9 Types of Offshore Entity
- 11.10 Overseas Trading
- 11.11 UK Controlled Foreign Company (CFC) Rules
Chapter 12. Investing in UK Property: A Case Study
- 12.1 Direct Ownership
- 12.2 Using a Trust to Own the Property
- 12.3 Using an Offshore Company
- 12.4 Conclusion
Chapter 13. Becoming a Tax Nomad
Chapter 14. Double Tax Treaties
- 14.1 How Double Tax Treaties Work
- 14.2 What a Typical DTT Looks Like
- 14.3 The UK-Isle of Man Double Tax Treaty
- 14.4 Using Double Tax Treaties to Save Tax
- 14.5 Treaty Relief
- 14.6 Considering a Move to Spain
Chapter 15. Buying Property Abroad
- 15.1 Introduction
- 15.2 UK Resident/Ordinarily Resident and Domiciled
- 15.3 Non-Resident/Ordinarily Resident and Non-UK Domiciled
- 15.4 UK Resident/Ordinarily Resident and Non-UK Domiciled
- 15.5 Use of an Offshore Company/Trust
- 15.6 Using Mixed Residence Partnerships to Avoid CGT
- 15.7 What About Overseas Tax Implications?
- 15.8 Double Tax Relief (DTR)
- 15.9 Summary
Appendix: UK-Spain Double Tax Treaty