.jpg)
Finance bill 2008: Residence and domicile review
This article is an extract from the article 'Finance Bill 2008: Residence and domicile review' prepared by Mads Birkeland (mb@correntroen.com or 020 7592 8932) and Benedikte Malling (bm@correntroen.com or 020 7592 8936)
Please click hereforthe full article
Following months of intense debate the Finance Bill published on 27th March 2008 introduces significant changes to the taxation of resident and non domiciled individuals and important diversions and clarifications on proposals previously put forward. Notably it includes a foreign domicile charge, changes to the remittance basis of taxation and changes to the method of counting days for determining UK residence.
While this briefing sets out the main proposals the debate continues as to whether the Finance Act to be passed this summer will take the substantial form set out in the Finance Bill. The exact rules and effects of the future legislation which will apply as of 6 April 2008 therefore remains unclear.
Domicile Charge The draft legislation ends the automatic entitlement for foreign domiciled individuals to claim that any foreign income or any gains on assets situated overseas are only subject to UK tax if, and to the extent that, the income or gains are remitted to the UK: - All individuals that elect to claim the remittance basis of taxation will loose their entitlement to claim personal allowances and the capital gains tax annual allowance unless the unremitted income and gains are less than £2,000. - Foreign domiciled adult individuals (aged 18 and over at the end of the tax year) who have been resident in the UK for 7 out of the previous 10 tax years and wish to take advantage of the remittance basis of taxation will be subject to a £30,000 annual charge. - The annual charge takes the form of a tax charge on any foreign income or gains that has arisen but been remitted during the tax year. Individuals paying the charge will choose what foreign income or gains the charge is paid on subject to careful planning. Consequently, this will not be taxed again when, or if, it is eventually remitted to the UK. - The charge will not apply if the unremitted income and gains are less than £2,000. - Individuals who, elect to pay the charge will remain subject to tax on categories of foreign income and capital gains only to the extent these are remitted to the UK. - Individuals who do not elect to be taxed on the remittance basis will be liable to tax on worldwide income and gains on an arising basis in the year in which the income is earnt or the gain is made. - The proposal provides relief for offshore capital losses incurred in years where the individual is taxed in the UK on arising basis. - Deposits in non-sterling currencies will be constitute an investment and capital gains may arise on the disposal of the currencies. - Individuals can opt in and out of the remittance basis of taxation on an annual basis, and a non-payment does not make the individual UK domiciled. - The charge is per tax-payer, not per household. - Individuals resident in another territory by virtue of a relevant Double Taxation Agreement will not be subject to the charge. - As the charge will be classified as either income tax or capital gains tax (rather than a stand alone charge), the Treasury intends for it to be treated as such for the purpose of any Double Taxation Agreement to provide relief against any tax which might be levied in the individual’s country of domicile on the same income. - The Treasury is considering the tax treatment of dual resident individuals who pays tax in a country which does not have a Double Taxation Agreement with the UK.
To read more, please click here
CHURT PROPERTY MANAGEMENT Ltd (CHURT) operates within prime residential leasehold properties with less than 20 years to expiry of An originally long leasehold. CHURT operates as principals and with a limited number of investors seeking safe investments with an attractive yield.
We wish to BUY:
Prime residential leasehold properties with less than 20 years left to expiry of an originally long leasehold.
We offer to RENT:
Prime residential flats and houses in Belgravia, Knightsbridge, Mayfair and St. James to rent
Contact details: details:
Churt Property Management Ltd
Torben Dal
Borrow House
Jumps Road
Farnham
Surrey
GU10 2LB
Tel: 01252 795 641
Email: tdal@churtproperty.com
www.churtproperty.com
Want to set up a new office, plant or R&D facility in the UK? or expand your existing UK business? We can help!
The UK's vibrant economy offers companies a springboard for growth. Danish companies can capitalize on this through advice from UK Trade & Investment!
UK Trade & Investment (www.ukinvest.gov.uk) is the UK Government's international business development organisation. We can help you with:
- - Location analysis to help you choose the right place to do business.
- - Tailored information on, for example, company formation, the labour market and skills, and office premises
- - Advice on financial assistance e.g. R&D tax credits and grants
- - Introductions to the network of regional contacts in England, Scotland, Wales, and Northern Ireland
- - Access to the full range of R&D resources throughout the UK
- - Identifying potential UK collaboration partners
UK Trade & Investment can also offer you unique assistance with regulatory issues, access to industry networks around UK centres of excellence, as well as introductions to sector leaders and business contacts. We can act as a voice of government for your business interests and offer continued support through our in-house investor development network which provides assistance to you once you have established a presence in the UK to ensure you will develop and prosper. Individuals with exceptional talents or intellectual property can benefit from our Global Entrepreneur Programme, enabling entrepreneurs or early stage companies from Denmark to globalise their businesses from a UK base. All our services for Danish Businesses are FREE and confidential For more information on how we can help you realise your company's business potential, contact Matthew Delany, UK Trade & Investment, British Embassy Copenhagen, on matthew.delany@fco.gov.ukor +45 35 26 63 75
23 June - Champagne Reception at 1 Lombard Street with Creative Nation and Danes Abroad
10 July - Summer Cocktail Party
24 September - Danish Design in a Global Context
29 October - Danish Design: An Evening with Bang & Olufsen
19 November - Danish Design, Focus on furniture
12 December - DUCC Christmas Lunch
Nordic Thursday Drinks take place the last Thursday of every month at the Radisson SAS Portman Hotel.
We are in addition to the above scheduled events still waiting for a few dates and venues to be confirmed. Please stay updated by visiting www.ducc.co.uk regulary.
|