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