This document provides an overview of remittances and bank account structures for non-UK domiciled individuals. It discusses topics such as overseas work day relief, mixed funds, clean capital, types of accounts, capital gains, remittances with foreign tax credits, and exempt property. Planning ideas are also presented, such as transferring funds between accounts to minimize tax liabilities when making remittances to the UK.
This document summarizes Taiwan's Alternative Minimum Tax (AMT) system, including:
1) AMT applies to both onshore and offshore income of ROC residents from 2006 onward. Offshore income was added in 2010.
2) The AMT, called "Basic Income Tax", calculates tax based on an individual's "basic income" which includes regular and offshore income, at a rate of 20% on amounts over NT$6 million.
3) Offshore income includes various categories like business, professional, salary, rental, and investment income earned outside of Taiwan.
Accountingfor Income Tax Uncertainties 2010 K Morris ShKatherineMorris
This document summarizes key aspects of accounting for income tax uncertainties, including:
1) Guidance on evaluating uncertain tax positions under ASC 740, including the "more likely than not" recognition threshold and two-step measurement process.
2) Common issues like applying the guidance to pass-through entities, non-profits, accounting method changes, audit settlements, and valuation allowances.
3) Required disclosures for public and non-public companies, including tabular rollforwards and descriptions of uncertain tax benefits that affect the effective tax rate.
Report any gambling winnings as income on your tax return. Be sure you itemize to deduct gambling losses up to the amount of your winnings. If you are a casual gambler, these tax tips can help:
Session 3/3 Day 1. Audio Commentary by Anthony Williams (FPFA,LLB) to be added soon. For 1 on 1 discussion call +92-321-4409009, 0321-4409009, 92-42-35925972
International Tax and Transfer Pricing TopicsSkoda Minotti
This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
The document discusses a Receipt and Payment Account, which summarizes cash and bank transactions under various heads based on a cash book. It is prepared at the end of the accounting year to help prepare the Income and Expenditure Account and Balance Sheet. Receipts are recorded on the debit side and payments on the credit side. It shows total receipts and payments under different categories but does not disclose accurate income/expenditure or a surplus/deficiency as it is not prepared on an accrual basis.
The document discusses ways to make completing a self-assessment tax return easier. Most UK citizens have taxes automatically deducted, but around 11.5 million are expected to file returns this year if they are self-employed, own a limited company, earn over £100,000, or have other sources of untaxed income. The document provides tips for filing returns, such as gathering all relevant documents like P60/P45/P11D forms in advance.
This document summarizes Taiwan's Alternative Minimum Tax (AMT) system, including:
1) AMT applies to both onshore and offshore income of ROC residents from 2006 onward. Offshore income was added in 2010.
2) The AMT, called "Basic Income Tax", calculates tax based on an individual's "basic income" which includes regular and offshore income, at a rate of 20% on amounts over NT$6 million.
3) Offshore income includes various categories like business, professional, salary, rental, and investment income earned outside of Taiwan.
Accountingfor Income Tax Uncertainties 2010 K Morris ShKatherineMorris
This document summarizes key aspects of accounting for income tax uncertainties, including:
1) Guidance on evaluating uncertain tax positions under ASC 740, including the "more likely than not" recognition threshold and two-step measurement process.
2) Common issues like applying the guidance to pass-through entities, non-profits, accounting method changes, audit settlements, and valuation allowances.
3) Required disclosures for public and non-public companies, including tabular rollforwards and descriptions of uncertain tax benefits that affect the effective tax rate.
Report any gambling winnings as income on your tax return. Be sure you itemize to deduct gambling losses up to the amount of your winnings. If you are a casual gambler, these tax tips can help:
Session 3/3 Day 1. Audio Commentary by Anthony Williams (FPFA,LLB) to be added soon. For 1 on 1 discussion call +92-321-4409009, 0321-4409009, 92-42-35925972
International Tax and Transfer Pricing TopicsSkoda Minotti
This document provides an overview and agenda for topics related to international taxation and transfer pricing. It discusses general U.S. tax principles, income tax treaties, the foreign tax credit, international filing requirements, and transfer pricing. Specific items covered include the U.S. tax treatment of foreign persons and U.S. persons, anti-deferral regimes like Subpart F and PFIC, and documentation requirements for forms like 5471, 8865, and 8858.
The document discusses a Receipt and Payment Account, which summarizes cash and bank transactions under various heads based on a cash book. It is prepared at the end of the accounting year to help prepare the Income and Expenditure Account and Balance Sheet. Receipts are recorded on the debit side and payments on the credit side. It shows total receipts and payments under different categories but does not disclose accurate income/expenditure or a surplus/deficiency as it is not prepared on an accrual basis.
The document discusses ways to make completing a self-assessment tax return easier. Most UK citizens have taxes automatically deducted, but around 11.5 million are expected to file returns this year if they are self-employed, own a limited company, earn over £100,000, or have other sources of untaxed income. The document provides tips for filing returns, such as gathering all relevant documents like P60/P45/P11D forms in advance.
This document summarizes key information for foreign investors looking to invest in Spain in 2015. It outlines the regulated sectors for foreign investment, classifications of tax residents and non-residents, and considerations for establishing a branch or subsidiary. It also provides an overview of corporate and individual taxation, real estate investments, VAT rules, and advantages of the Canary Islands Special Zone for reduced corporate tax rates. Finally, it summarizes Spain's "Golden Visa" program which provides residence permits for foreign investors making certain minimum investments in Spain.
The document discusses the accounting for not-for-profit organizations. It describes the three main financial statements used: the receipts and payments account, income and expenditure account, and balance sheet. The receipts and payments account is prepared at the end of the year based on cash receipts and payments. It summarizes all cash and bank transactions under various heads, including opening and closing balances. Revenue receipts include items like membership dues and donations, while capital receipts include loans or assets received. Revenue payments are recurring expenses, and capital payments provide benefits for future years like asset purchases.
The document discusses India's balance of payments and current account. It provides an agenda covering introduction, calculation, ways to reduce the current account deficit, trends in India's balance of payments and current account, and a conclusion. Some key points include:
- The current account balance is calculated as exports minus imports plus net income and transfers. India has experienced a current account deficit in recent years.
- Ways to reduce the deficit include devaluing the currency, implementing deflationary policies, supply side reforms, and protectionism. However, protectionism could backfire.
- Trends show India's current account deficit narrowed in the first quarter of 2014 due to higher exports and lower imports including a large drop in gold
The document discusses common mistakes made in filing income tax returns in India for the 2014-15 assessment year. Some key mistakes include leaving deductions blank without providing amounts, incorrectly claiming deductions by not meeting criteria or limits, and exceeding the total income amount with deductions. Mistakes can also occur from incorrectly computing income subject to special tax rates like capital gains. Providing inaccurate personal details like date of birth or gender can also impact tax computations. Failure to fully pay taxes due by the due date or having a shortfall in advance tax payments can result in interest charges under various sections.
This document discusses a UK court case regarding the tax treatment of depreciation for businesses that store products in depreciating assets over several years. Specifically, it addresses whether the full depreciation amount or net depreciation needs to be added back for tax purposes. The UK High Court and Scottish Court of Session initially ruled that the full amount must be added back. However, the UK House of Lords overturned this, finding that only the net depreciation amount deducted from profits needs to be added back for tax. This House of Lords decision should also apply persuasively to similar cases in Ireland.
The document defines and explains the concept of balance of payments. It discusses the components of balance of payments including visible and invisible trade, current accounts, capital accounts, and official reserves. It also covers the effects of a positive versus negative balance of payments and makes suggestions to improve a country's balance. Specific details on Pakistan's trade deficit in September 2016 are provided. Key sources and a quotation are listed at the end.
Cencosud reported financial results for the third quarter of 2015. While revenue growth was modest due to currency depreciation, most businesses saw positive same-store sales growth in local currencies. Adjusted EBITDA increased year-over-year excluding one-time severance and inventory charges totaling $49 million. The company is adjusting its asset base to focus on core retail operations and improving margins through cost controls and inventory management. Cencosud is also considering an IPO of its shopping center business and selling non-core assets in Colombia.
The Finance Act 2015 - How does it affect your clients? By CBW TaxRobert Maas
How will the many significant changes in the Finance Act 2015 affect your clients?
Let us share with you our thoughts on all of the main changes in the Finance Act.
The document provides an overview of international assignee tax services and the different tax treatment arrangements for expatriate employees, including tax equalization, tax protection, and a laissez-faire arrangement. It summarizes the tax implications of each arrangement using a hypothetical example where an employee earns $100,000 and is assigned to a country with a 20% tax rate from a home country with a 30% tax rate. It also briefly discusses UK tax residence rules, social security considerations, and other issues that an international assignee tax services firm can assist with.
Tax Treatment of Non-UK Domiciled PersonsNaddir Muthu
Reforms to the tax treatment of non-UK domiciled persons
The use of overseas Trusts for non-UK domiciled persons
The use of non-Trust solutions for former UK domiciles and UK persons
Reforms to IHT on UK residential property held through overseas companies
Alison Vine, Director at Deloitte, gives practical and concise update on all the latest tax and NIC developments, topical tax issues, planning you will need to be aware of, and the impact of these changes on your clients and your business.
Alison Vine, Tax Director, Deloitte offers a practical and concise update on all the latest tax and NIC developments, topical tax issues, planning you will need to be aware of, and the impact of these changes on your clients and your business.
The document provides guidance on property letting taxes in the UK, including:
- Stamp Duty Land Tax is charged on property purchases at incremental rates up to 12% depending on the value, with higher rates for additional properties.
- Income from property lettings is taxed as income at income tax rates of up to 45% or corporation tax of 19% if owned through a company. Allowable expenses can be claimed to reduce taxable profits.
- Capital Gains Tax of 18% or 28% may apply on gains made from selling properties not eligible for the main residence exemption. Private letting relief provides exemption up to £40,000 per owner.
- Inheritance Tax at 40% applies to property value transferred between
The UK 2013 Budget Report summarizes key points from the UK's 2013 budget including:
- GDP growth expectations from 2013 to 2017 ranging from 0.6% to 2.8% annually
- Public sector net debt as a percentage of GDP expected to rise from 75.9% to 85.6% over the same period
- Corporate tax rates to be reduced from 23% to 21% and eventually a single 20% rate for all profits by 2015-16
- Individual tax allowances to increase annually through 2014
- Capital gains tax holiday to be extended and employment allowance for employer national insurance contributions introduced.
What does the budget means for you and your clients and, importantly, any tax planning opportunities for high net worth individuals and business owners.
Most observers do not believe that further curbs on public spending can reduce our debts to an acceptable level, thus suggesting that George will have to increase taxes in a way that will not hurt the average citizen. It also suggests that hopes of reforms that reduce tax yields are likely to prove unrealistic. In particular, an increase in the IHT limit (other than the promised limited relief for family homes) seems unlikely. We also expect further pain for non-doms and tax avoiders. We think that some tax relief for small businesses is likely, but as such businesses create scope for tax evasion and avoidance, we are sceptical as to how helpful these are likely to be in practice.
1) The UK had a current account deficit of £80 billion in 2016 according to the quick quiz.
2) The current account, capital account, and financial account make up the three components of a country's balance of payments.
3) A current account deficit means a country is a net borrower internationally, while a surplus means it is a net lender. The UK has had a persistent current account deficit for many years.
This document contains a summary of a budget presentation and survey results from last year. It discusses key points from the UK budget such as reductions to corporation tax and capital allowance changes to support business investment. It also outlines planned increases to personal income tax allowances and the lifetime pension allowance. Survey results are provided on economic forecasts and views on the economy from last year along with a new survey on business confidence after this budget.
Advice for learners on money related matters, includes, National Insurance, Tax codes & rates, minimum wage, interest rates, budget and debt advice. Activities included.
The Balance of Payments - How it's measuredHugo OGrady
The Balance of Payments - How it's measured content slideshow. Designed for the Economic A level qualification. Can be used in revision and in class.
Subtopics:
Intro to the Balance of Payments
The Current Account
Why does the Balance of Payments Always Sum to Zero?
The Interconnection of Economies through Trade
Your Taxes: Top 10 Things to Know & Tax Filing Tips and TrapsModernAdvisor
Faizal Valli is an independent tax advisor with 13 years experience in tax planning. He has previously worked with small accounting firms as well as an international tax firm and a boutique practice in taxes over a wide variety of experience.
In this presentation, we discuss the top 10 changes introduced in the federal budget which was presented on Tuesday, March 22nd. We review what you need to know about these tax changes that will affect you in 2016 and going forward. Next we’ll switch gears and talk about some tax tips and traps to be aware of for the 2015 filing season as well as generally.
Our Spring Tax Updates will be taking place across the region in March 2018.
The update will include the following:
• Comment on the latest legislative changes
• Provide practical advice
• Help to prepare for the end of the tax year
• Give thoughts on the current tax policy
Local Council Accounts_ From Zero to Hero!.pdfScribe
Scribe Academy™ Presents
📺 LOCAL COUNCIL ACCOUNTS - FROM ZERO TO HERO! **
YOU WILL DISCOVER:
• Super easy procedures to make sure your books balance.
• How VAT returns work and what scheme you should be using.
• The secrets to a straight forward year-end and getting the AGAR right.
Join our Head Accountant Hannah and learn how master your Council's accounts and go from zero to hero! This session is suitable for Clerks of all abilities regardless of council size and how the accounts are currently managed.
🗣️ Introducing Hannah Driver
Hannah Driver is the Head Accountant at Scribe. She has been with Scribe for 5 years and helped the company grow from 1 customer to over 750 customers. She has been training and supporting both small and large councils across England and Wales for the last 5 years. As you can imagine, Hannah has managed and solved all manner of accounting issues, we are lucky enough to have her in our team.
⚖️ Introducing Scribe Accounts
Scribe products are super easy to use, and purpose-built for parish, town and community councils. It's a cloud application accessible via a web browser on your desktop, laptop, iPad or mobile device.
Key Features Include:
✅ Transaction input and editing
✅ Bank Reconciliations
✅ VAT Returns to Making Tax Digital portal
✅ Invoicing & Purchase Orders
✅ Budgeting & Forecasting
✅ Annual Return/ Year-End
All Scribe products come with:
👩🏻🎓 Free Training
👐 Unlimited Support
🧑🏻🤝🧑🏻 Unlimited Users
👩💻 Unlimited Software upgrades
What to find out more?
💬 Just type “yes” in the zoom chat
or
🌐 https://www.scribeaccounts.com/features
📧 hello@scribeaccounts.com
☎️ 01603 856521
🚀 https://www.scribeaccounts.com/demo-request
This document summarizes key information for foreign investors looking to invest in Spain in 2015. It outlines the regulated sectors for foreign investment, classifications of tax residents and non-residents, and considerations for establishing a branch or subsidiary. It also provides an overview of corporate and individual taxation, real estate investments, VAT rules, and advantages of the Canary Islands Special Zone for reduced corporate tax rates. Finally, it summarizes Spain's "Golden Visa" program which provides residence permits for foreign investors making certain minimum investments in Spain.
The document discusses the accounting for not-for-profit organizations. It describes the three main financial statements used: the receipts and payments account, income and expenditure account, and balance sheet. The receipts and payments account is prepared at the end of the year based on cash receipts and payments. It summarizes all cash and bank transactions under various heads, including opening and closing balances. Revenue receipts include items like membership dues and donations, while capital receipts include loans or assets received. Revenue payments are recurring expenses, and capital payments provide benefits for future years like asset purchases.
The document discusses India's balance of payments and current account. It provides an agenda covering introduction, calculation, ways to reduce the current account deficit, trends in India's balance of payments and current account, and a conclusion. Some key points include:
- The current account balance is calculated as exports minus imports plus net income and transfers. India has experienced a current account deficit in recent years.
- Ways to reduce the deficit include devaluing the currency, implementing deflationary policies, supply side reforms, and protectionism. However, protectionism could backfire.
- Trends show India's current account deficit narrowed in the first quarter of 2014 due to higher exports and lower imports including a large drop in gold
The document discusses common mistakes made in filing income tax returns in India for the 2014-15 assessment year. Some key mistakes include leaving deductions blank without providing amounts, incorrectly claiming deductions by not meeting criteria or limits, and exceeding the total income amount with deductions. Mistakes can also occur from incorrectly computing income subject to special tax rates like capital gains. Providing inaccurate personal details like date of birth or gender can also impact tax computations. Failure to fully pay taxes due by the due date or having a shortfall in advance tax payments can result in interest charges under various sections.
This document discusses a UK court case regarding the tax treatment of depreciation for businesses that store products in depreciating assets over several years. Specifically, it addresses whether the full depreciation amount or net depreciation needs to be added back for tax purposes. The UK High Court and Scottish Court of Session initially ruled that the full amount must be added back. However, the UK House of Lords overturned this, finding that only the net depreciation amount deducted from profits needs to be added back for tax. This House of Lords decision should also apply persuasively to similar cases in Ireland.
The document defines and explains the concept of balance of payments. It discusses the components of balance of payments including visible and invisible trade, current accounts, capital accounts, and official reserves. It also covers the effects of a positive versus negative balance of payments and makes suggestions to improve a country's balance. Specific details on Pakistan's trade deficit in September 2016 are provided. Key sources and a quotation are listed at the end.
Cencosud reported financial results for the third quarter of 2015. While revenue growth was modest due to currency depreciation, most businesses saw positive same-store sales growth in local currencies. Adjusted EBITDA increased year-over-year excluding one-time severance and inventory charges totaling $49 million. The company is adjusting its asset base to focus on core retail operations and improving margins through cost controls and inventory management. Cencosud is also considering an IPO of its shopping center business and selling non-core assets in Colombia.
The Finance Act 2015 - How does it affect your clients? By CBW TaxRobert Maas
How will the many significant changes in the Finance Act 2015 affect your clients?
Let us share with you our thoughts on all of the main changes in the Finance Act.
The document provides an overview of international assignee tax services and the different tax treatment arrangements for expatriate employees, including tax equalization, tax protection, and a laissez-faire arrangement. It summarizes the tax implications of each arrangement using a hypothetical example where an employee earns $100,000 and is assigned to a country with a 20% tax rate from a home country with a 30% tax rate. It also briefly discusses UK tax residence rules, social security considerations, and other issues that an international assignee tax services firm can assist with.
Tax Treatment of Non-UK Domiciled PersonsNaddir Muthu
Reforms to the tax treatment of non-UK domiciled persons
The use of overseas Trusts for non-UK domiciled persons
The use of non-Trust solutions for former UK domiciles and UK persons
Reforms to IHT on UK residential property held through overseas companies
Alison Vine, Director at Deloitte, gives practical and concise update on all the latest tax and NIC developments, topical tax issues, planning you will need to be aware of, and the impact of these changes on your clients and your business.
Alison Vine, Tax Director, Deloitte offers a practical and concise update on all the latest tax and NIC developments, topical tax issues, planning you will need to be aware of, and the impact of these changes on your clients and your business.
The document provides guidance on property letting taxes in the UK, including:
- Stamp Duty Land Tax is charged on property purchases at incremental rates up to 12% depending on the value, with higher rates for additional properties.
- Income from property lettings is taxed as income at income tax rates of up to 45% or corporation tax of 19% if owned through a company. Allowable expenses can be claimed to reduce taxable profits.
- Capital Gains Tax of 18% or 28% may apply on gains made from selling properties not eligible for the main residence exemption. Private letting relief provides exemption up to £40,000 per owner.
- Inheritance Tax at 40% applies to property value transferred between
The UK 2013 Budget Report summarizes key points from the UK's 2013 budget including:
- GDP growth expectations from 2013 to 2017 ranging from 0.6% to 2.8% annually
- Public sector net debt as a percentage of GDP expected to rise from 75.9% to 85.6% over the same period
- Corporate tax rates to be reduced from 23% to 21% and eventually a single 20% rate for all profits by 2015-16
- Individual tax allowances to increase annually through 2014
- Capital gains tax holiday to be extended and employment allowance for employer national insurance contributions introduced.
What does the budget means for you and your clients and, importantly, any tax planning opportunities for high net worth individuals and business owners.
Most observers do not believe that further curbs on public spending can reduce our debts to an acceptable level, thus suggesting that George will have to increase taxes in a way that will not hurt the average citizen. It also suggests that hopes of reforms that reduce tax yields are likely to prove unrealistic. In particular, an increase in the IHT limit (other than the promised limited relief for family homes) seems unlikely. We also expect further pain for non-doms and tax avoiders. We think that some tax relief for small businesses is likely, but as such businesses create scope for tax evasion and avoidance, we are sceptical as to how helpful these are likely to be in practice.
1) The UK had a current account deficit of £80 billion in 2016 according to the quick quiz.
2) The current account, capital account, and financial account make up the three components of a country's balance of payments.
3) A current account deficit means a country is a net borrower internationally, while a surplus means it is a net lender. The UK has had a persistent current account deficit for many years.
This document contains a summary of a budget presentation and survey results from last year. It discusses key points from the UK budget such as reductions to corporation tax and capital allowance changes to support business investment. It also outlines planned increases to personal income tax allowances and the lifetime pension allowance. Survey results are provided on economic forecasts and views on the economy from last year along with a new survey on business confidence after this budget.
Advice for learners on money related matters, includes, National Insurance, Tax codes & rates, minimum wage, interest rates, budget and debt advice. Activities included.
The Balance of Payments - How it's measuredHugo OGrady
The Balance of Payments - How it's measured content slideshow. Designed for the Economic A level qualification. Can be used in revision and in class.
Subtopics:
Intro to the Balance of Payments
The Current Account
Why does the Balance of Payments Always Sum to Zero?
The Interconnection of Economies through Trade
Your Taxes: Top 10 Things to Know & Tax Filing Tips and TrapsModernAdvisor
Faizal Valli is an independent tax advisor with 13 years experience in tax planning. He has previously worked with small accounting firms as well as an international tax firm and a boutique practice in taxes over a wide variety of experience.
In this presentation, we discuss the top 10 changes introduced in the federal budget which was presented on Tuesday, March 22nd. We review what you need to know about these tax changes that will affect you in 2016 and going forward. Next we’ll switch gears and talk about some tax tips and traps to be aware of for the 2015 filing season as well as generally.
Our Spring Tax Updates will be taking place across the region in March 2018.
The update will include the following:
• Comment on the latest legislative changes
• Provide practical advice
• Help to prepare for the end of the tax year
• Give thoughts on the current tax policy
Local Council Accounts_ From Zero to Hero!.pdfScribe
Scribe Academy™ Presents
📺 LOCAL COUNCIL ACCOUNTS - FROM ZERO TO HERO! **
YOU WILL DISCOVER:
• Super easy procedures to make sure your books balance.
• How VAT returns work and what scheme you should be using.
• The secrets to a straight forward year-end and getting the AGAR right.
Join our Head Accountant Hannah and learn how master your Council's accounts and go from zero to hero! This session is suitable for Clerks of all abilities regardless of council size and how the accounts are currently managed.
🗣️ Introducing Hannah Driver
Hannah Driver is the Head Accountant at Scribe. She has been with Scribe for 5 years and helped the company grow from 1 customer to over 750 customers. She has been training and supporting both small and large councils across England and Wales for the last 5 years. As you can imagine, Hannah has managed and solved all manner of accounting issues, we are lucky enough to have her in our team.
⚖️ Introducing Scribe Accounts
Scribe products are super easy to use, and purpose-built for parish, town and community councils. It's a cloud application accessible via a web browser on your desktop, laptop, iPad or mobile device.
Key Features Include:
✅ Transaction input and editing
✅ Bank Reconciliations
✅ VAT Returns to Making Tax Digital portal
✅ Invoicing & Purchase Orders
✅ Budgeting & Forecasting
✅ Annual Return/ Year-End
All Scribe products come with:
👩🏻🎓 Free Training
👐 Unlimited Support
🧑🏻🤝🧑🏻 Unlimited Users
👩💻 Unlimited Software upgrades
What to find out more?
💬 Just type “yes” in the zoom chat
or
🌐 https://www.scribeaccounts.com/features
📧 hello@scribeaccounts.com
☎️ 01603 856521
🚀 https://www.scribeaccounts.com/demo-request
The Summer Budget 2015 document provides an overview and analysis of the key announcements from the UK Summer Budget 2015. It discusses changes to personal taxes including increases to the personal tax allowance and higher rate tax threshold. It also covers reforms to inheritance tax, including a new main residence nil rate band. Business tax measures are analyzed such as reductions to the corporation tax rate and changes to dividend taxation and annual investment allowance limits.
The document summarizes the UK tax rules regarding the remittance basis for taxation of foreign income and gains for non-UK domiciled individuals. It discusses who qualifies for the remittance basis, what constitutes a taxable remittance, and recent cases related to residency and domicile status. It also provides an overview of how the remittance basis rules are applied in practice and considerations around segregating different types of income and gains.
This document provides a high-level overview of tax regimes around the world from the BDO Tax Global Opportunities Report. It discusses various categories of tax regimes such as low/no tax countries, countries with a remittance basis of taxation, and countries favorable to new residents. The report then provides brief summaries of the tax systems in various regions, including Europe/Middle East, Americas/Caribbean, and Asia Pacific. It concludes by considering the most popular jurisdictions for entrepreneurs, global executives, and pensioners seeking to relocate.
Our Spring Tax Updates will be taking place across the region in March 2018.
The update will include the following:
• Comment on the latest legislative changes
• Provide practical advice
• Help to prepare for the end of the tax year
• Give thoughts on the current tax policy
The document summarizes hot topics related to VAT (Value Added Tax) in the UK, including:
1) VAT registration requirements and thresholds for compulsory and voluntary registration.
2) Schemes for flat rate, cash accounting and annual accounting VAT payments that provide benefits for small businesses.
3) Rules around VAT liability, rates, discounts, bad debt relief and voluntary disclosures.
4) Future changes including a potential VAT rate increase and complex areas like property and services.
Similar to Bank Account Structuring for Non-Domiciles (20)
1. REMITTANCES AND BANK ACCOUNT
STRUCTURES FOR NON-UK DOMICILED
INDIVIDUALS
Nick Knight – Spring 2016
2. "The trick is to stop thinking
of it as 'your' money" - IRS
auditor
3. Agenda
Overseas Work Day Relief
Mixed Funds – why these should be avoided (where possible)
‘Clean capital’
Types of Accounts
Beware of Capital Gains
Remember to calculate remittances using UK rules
Remittances with FTC attached
Remittances and the arising basis
Exempt Property
Planning ideas
Accounts to use in the UK and those not to touch
4. Overseas Work Day Relief (OWDR)
• Available for first three years of UK-tax residence for non-UK domiciles
• Can be claimed anew, but only if returning to the UK after three years of non-
UK tax residence
• Earnings must be paid into a qualifying non-UK account and amount of
OWDR claimed must never be brought into the UK as cash
• OWDR claim will almost certainly lead to loss of PA (if otherwise due) and
CGT annual exemption under £2K rule, so these need to be considered
• For US nationals, anything that escapes UK taxation will then still be taxed in
the US, but now with no FTC, meaning that even more saving is needed to
make this worthwhile
• Many may feel sacrifices needed to claim OWDR are not worthwhile,
especially if they are tax equalised and not paying the UK tax in any case.
5. Overseas Work Day Relief – Qualifying Account
• Old SP1/09 accounts now replaced by Special Mixed-Fund Accounts
• Where accounts qualify then there are deemed to be two transactions, firstly ‘UK
remittances’ and then ‘offshore transfers’ (everything else, including non-UK spending from
the account) at the end of the UK tax year
• This makes things simpler, but there are specific conditions for the qualifying accounts:
• Only one is permitted at any one time
• It must be nominated and reported as such on the relevant UK tax return, with the date
it became so (which must be before the date of the first payment into it)
• Account must only receive income from a single employment and interest from the account
(anything else is a ‘tainting event’ which would disqualify the account after three times in
any twelve-month period, if ‘tainting’ not reversed within 30 days)
• Ideally there is a new account each year (but not always practical), otherwise must be
reduced to under £10 before first earnings payment in new UK tax year
• Split-year arrival cases problem (see below) – better to be NR for arrival year.
6. OWDR – Split-year problem for qualifying account
• Account needs to be nominated before the first payment of general earnings into
the account in the UK tax year
• The definition of ‘general earnings’ will include pre-arrival earnings
• At beginning of UK tax year any UK assignment may not be envisaged and so
election unlikely to be made in time
• Account would therefore not qualify and usual strict tracking rules would need to
apply
• NR in first year alleviates this issue, as does opening a new account to be the
qualifying account as soon as (or just before) the UK assignment commences
7. OWDR – Avoiding ‘Trapped’ relief
• As current-year income is deemed to be remitted before that of previous years, clearing
the account at the year end to stop ‘trapped’ relief is important
• Once tax return is prepared, actual level of OWDR can be determined (i.e. amount that
must remain outside the UK), with anything above this remitted to the UK without further
charge (being already taxed UK earnings). NB: it is necessary to remit the non-OWDR
income, due to ‘offshore transfer’ identification rules (see below)
• The OWDR funds should all be put into an account that is NEVER remitted to the UK
(either directly or indirectly)
• All OWDR funds for various years can go into the same account, with any interest
credited into a specific interest account
• OWDR funds will be taxable even if remitted in years of non-UK tax residence (the only
such example of this?).
8. OWDR Funds – Practical example
• Mary earns £200K a year, which is paid into a nominated qualifying account for OWDR (she keeps the
same account for her salary while in the UK). She arrived in 2014/15 and was resident for that year.
• She anticipates 10% non-UK work days for 2015/16, but keeps 20% in the account to be on the safe
side, remitting the balance to her London account to cover her UK living expenses.
• On 4 April 2016 she transfers £40K (the 20%) to a new non-UK holding account (her first pay day for the
new UK tax year is 16 April, being paid semi-monthly).
• The interest from this new account is paid into an interest-only account outside the UK until closed
• Mary’s UK tax return is filed on 15 September, showing 15% non-UK workdays
• Available OWDR is therefore £30K (15% x £200K) being lower than the £40K kept outside the UK.
• Mary closes the holding account and transfers £30K to her OWDR account (that she uses to fund costs
when she travels home) after remitting the remaining £10K to her UK account (which is income that has
already been taxed in the UK and is deemed to be remitted first).
• NB: If no transfer out of the account had taken place in April then the £10K would have become ‘trapped’
behind 2016/17 earnings and so could not be brought into the UK without foregoing any 2016/17 OWDR
(unless a new nominated account was opened).
• Another option would be to operate a split salary – 20% paid into non-UK account and 80% into the UK
account with the same year-end operation, as above.
9. Mixed Funds – ‘Do I not like that!’
• This is an account comprising more than one type of income or gains, or the same
income and gains relating to different tax years (so special accounts for OWDR are a
simple version of a mixed-fund account)
• A mixed fund will have deemed ordering rules where remitted to the UK, with non-
taxable ‘clean capital’ after everything else (broadly employment then other income,
then gains, then income with FTC, gains with an FTC, finally other ‘clean capital’)
• Current year funds are deemed to be remitted first, then PY1, PY2, etc.
• Where transferred to another non-UK account or spent outside the UK, the ordering
rules do not apply. Rather the relevant percentage of each source is deemed to be
transferred or spent each transaction (with the former this may in itself create a new
mixed fund account). These are both known as ‘offshore transfers’
• Tracking will only be required for accounts where funds are to be remitted to the UK, but
the best thing to do is to keep the different types of funds entirely separate, which keeps
things simple and leaves more options for remittances.
10. Offshore Transfer example (to show how onerous it can be)
• £10,000 in account - £6,000 clean capital, £1,000 foreign interest and £3,000 foreign
capital gains
• Three spending transactions totalling £100 on consecutive days, with each transaction
needing to be split between the different funds as follows:
Clean Interest Capital Gains Balance
6,000 1000 3,000 10,000
Cigarettes -6 -1 -3 -10
5,994 999 2,997 9,990
Petrol -24 -4 -12 -40
5,970 995 2,985 9,950
Football ticket -30 -5 -15 -50
5,940 990 2,970 9,900
11. ‘Clean Capital’
What is ‘Clean Capital’?
• Pre-UK tax residence income and gains/losses
• Taxed UK income
• Inheritance
• Gambling winnings
• Outright gifts (so beware artificial gifts for the benefit of the donor)
• Anything else that isn’t taxable in the UK (such as – usually - proceeds from the
sale of a private car, home sold where full PPR available, etc.)
NB: These can all be put together in the same ‘clean capital’ account, as it can all be
remitted tax-free to the UK, but the interest should be credited to a specific account for
interest
12. Possible different non-UK account types
Will depend on sources held and level of funds, but in
theory all of these may be appropriate (for very HNWI):
• Clean Capital Account
• OWDR (‘Special Mixed-Fund’) account (and possibly ‘holding account’, as above)
• Rental income account
• Interest account* (possibly split between taxed and untaxed)
• Dividend account
• Capital Gains account (split where mixture of gains subject/not subject to a foreign
tax, as the latter is always deemed to be remitted first)
• Capital losses account
(*The interest earned on all other non-UK accounts should be paid into this)
13. Suggested account structure (OWDR year example)
Holding
account (for
year end) –
remit to UK
account
then
OWDR
account
once levels
known
Non-UK account
for salary (leave
OWDR element
here during year)
Clean Capital
Account (remit
freely to UK
account from
here
UK Mainland
account (for
UK living
expenses)
Interest account (all interest from non-UK accounts paid
into this account)
OWDR (never
remit to UK)
Capital Gains
14. Suggested account structure (non-OWDR year example)
Clean Capital
Account (remit
freely to UK
account from
here
UK Mainland
account
(salary paid
into this)
Interest account (all interest from non-UK accounts paid
into this account)
OWDR (never
remit to UK)
Capital Gains
15. Beware of Capital Gains
When is a ‘gain’ not a ‘gain’ (or a ‘loss’ not a ‘loss’?)
• Remember that exchange rates may change a foreign gain to a loss or vice versa due to
exchange rate differentials as at the purchase and sale dates
• For example, if Hank both buys and sells his investment property for $1.2 million then he (quite
rightly for home-country purposes) thinks he has no gain or loss.
• However, from a UK perspective the situation may be very different.
• If the exchange rate was $1.8 to £1 at purchase (£666,667) and $1.2 at sale (£1,000,000)
then for UK tax purposes there is a £333,333 gain (or loss if the rates are reversed)
• Until the sale takes place we wouldn’t know whether the proceeds should go into the capital
gains or the capital losses account (assuming Hank had both), so should initially be put into a
separate holding account (where there are other gains/losses that have already been banked).
• Always watch out for foreign exchange rate issues like this, as they can give an extremely
distorted picture (the sterling to US$ exchange rate has fluctuated broadly in line with the
above in recent years, for example, so this is not far fetched).
• Sterling has weakened against most currencies in recent years, meaning that exchange rate
gains are more likely than losses (lower base cost, as with example above).
16. Remember to calculate using UK rules
• When calculating remitted income remember to calculate this using UK rules, as methods
will vary from country to country and may give vastly different results
• For example, some countries (USA and Australia) will give relief for depreciation against
rental income, whereas the UK does not. As such, for UK purposes any profit is likely to
be higher than in the home country, meaning if remitting rental income from these
countries there may be no FTC to use, or else a lower amount than expected.
• Similarly, there may be different rules for calculating capital gains in other countries (such
as the above, where the depreciation relief is then ‘clawed back’ at sale), or there may not
even be a capital gains tax at all (Hong Kong, Malaysia, New Zealand, etc.).
• Clients need to be aware that the UK tax treatment may be very different to that in the
country of origin of a gain or income.
17. Remittances with an FTC attached
• The remittance is net of the foreign tax rate (so we need to know this)
• This then has to be grossed-up at the foreign tax rate to give the deemed remittance
• The FTC is then based on the gross amount
• Residual liability where UK marginal rate is higher than FTC rate
• See the following for examples:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/323623/hs26
4.pdf
• Simple example from this is shown on next slide
18. Remittances with FTC attached (HMRC example)
• Jenny is taxable on the remittance basis and is liable to UK tax at the rate of 40%.
• Interest of £9,000 is paid into her foreign bank account after deduction of tax in the‘other’ country at the rate of 10% which
is available as a credit against UK tax on that income.
• Jenny decides to remit £4,500 of this interest to the UK.
• As Jenny has remitted half of the net amount of the interest she was paid, she is able to claim half of the admissible
foreign tax as a credit against UK tax on the income.
• Jenny must pay UK tax as follows:
• Gross income £10,000
• Foreign tax £1,000
• Net amount £9,000
• Remitted amount £4,500
• Available Foreign Tax Credit Relief (FTCR) £500
• (half the income has been remitted and so half the foreign tax is available as a credit against UK tax)
• Taxable amount £5,000
• UK tax (40%) £2,000
• minus FTCR £500
• Amount to pay £1,500
19. Remittances and the arising basis
• If an individual is filing on the arising basis, you may well think that remittances do not have
to be considered
• However, if the individual was previously filing on the remittance basis (and changed to the
arising basis to avoid the RBC, for example) any funds relating to the remittance basis
years will still be subject to the same rules, including mixed funds (where held)
• We should not see this very often, but it is something to bear in mind
• See Taxation article on this:
http://www.taxation.co.uk/taxation/Articles/2016/01/19/334219/readers-forum-arising-
remittance
20. Exempt Property
In certain circumstances it is possible to remit goods (not cash) without there being a tax
charge on this, where the remittance falls under one of the following headings:
• Property that meets the public access rule (for paintings, etc.)
• Clothing, footwear, jewellery and watches which meet the personal use rule
• Property of any description which meets the repair rule (furniture only in UK for repair, for
example)
• Property of any description which meets the temporary importation rule (in UK for fewer
that 275 ‘countable days’)
• Property where the notional remitted amount is less than £1000 (per item)
We are most likely to see the ‘personal use’ rule, but more details on all these are here:
https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm34000
21. Making offshore transfers minimise tax liabilities
• At first glance doing this wouldn’t seem to make any difference, but it can do if the whole
amount is not being remitted.
• Example: need to remit £10,000 from a £100,000 account that is 90% clean and 10%
interest. Liability can be reduced as follows:
Straight transfer
Clean Interest Balance
90,000 10000 100,000
Direct remittance 0 -10000 -10,000
90,000 0 90,000
Gives £10,000 taxable remittance
22. Transfer then remit funds
Making offshore transfers minimise tax liabilities
Clean Interest Balance
90,000 10000 100,000
Xfer to new account -9000 -1000 -10000
81,000 9000 90,000
New account make up 9,000 1000 10,000
Direct remittance -9000 -1000 -10000
0 0 0
Gives £1,000 taxable remittance
23. Other planning ideas
• Remit taxed income or gains where overseas rate paid is higher than rate payable in the UK (as
no additional tax then payable).
• It may even be worth having separate accounts for the same type of income, but with differing
FTC rates from different countries (if income held in multiple countries)
• If making a foreign rental loss (for UK purposes), then pay the related expenses outside the UK
from a different account to the rental income account (ideally one where you can never bring the
funds into the UK). Rental income funds can then effectively be brought into the UK tax free
(although reported as foreign rental), as there is nothing to say the expenses have to be
operated out of the same account, in the same way that capital gains do not have to be paid into
the same account from which the original purchase is made. (How new mortgage interest rules
would work in this scenario is a different matter)
• Same principle for Self-Employed earnings (if we see these)?
• Remit ‘exempt property’ purchased abroad from OWDR account with no charge?
• Set up a trust (but highly specialised and complex)
• However, the golden rule is that advice should always be sought in advance of making any
remittances to the UK and we need to highlight this fact at arrival briefings
24. Accounts to use (or possibly use) for remittances
• Clean capital (always tax free)
• Capital loss account (you cannot remit a loss, so these are tax free)
• Accounts with an FTC higher than rate due in the UK (but check how gain/income calculated)
• Rental income account (where net loss or nil gain for UK purposes)
• Accounts with an FTC slightly under rate due in the UK (after the above exhausted, as residual
liability will be lower)
• Capital Gains account (where an annual exemption is available – manipulate remittance to give
a gain close to this, but ensure gain correctly calculated)
• If all else fails then other Capital Gains could be remitted - lower tax rates vs income tax
• OWDR income and interest should not be remitted to the UK wherever possible (or have a UK
loan secured on these funds, per recent HMRC guidance), as these will attract tax rates up to
45%. These should be used to fund expenses for home trips or non-UK holidays (but then
remember not to bring anything significant back to the UK as this would constitute a remittance
to the UK if not ‘exempt property’ such as clothes and jewellery)