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main page from jump to: navigation , search this site provides comprehensive information about: taxation of foreign domiciliaries taxation of non-residents on uk income and assets taxation of uk residents on foreign income and assets it is the online version of taxation of non-residents and foreign domiciliaries by james kessler qc . contents update introduction 1 foreign domicile: tax policy 2 tax avoidance 3 domicile 4 deemed domicile 5 residence of individuals 6 residence of trustees 7 treaty-residence 8 exit taxes 9 split years: arrival and departure 10 temporary non-residence 11 source/relevant foreign income 12 the remittance basis 13 the meaning of remittance 14 remittance reliefs 15 mixed funds 16 trading income 17 trading in land 18 performers 19 property income 20 deduction of interest from property income 21 interest income 22 exempt interest of non-residents 23 dividend income 24 royalty income 25 misc sweep-up income 26 employment income 27 travel expenses: employment income 28 paye 29 employment income: dt relief 30 pension and annuity income 31 discretionary trusts: income tax 32 iip trusts: income tax 33 settlor-interested trust code 34 transfer of assets abroad: introduction 35 transfer of assets abroad: transferors 36 transfer of assets abroad: benefits 37 transfer of assets abroad: relief from overlapping charges 38 transfer of assets abroad: motive defence 39 profit fragmentation 40 life policies and contracts 41 offshore funds: definition 42 offshore income gains 43 income from offshore funds 44 accrued income profits 45 deeply discounted securities 46 unit trusts 47 intermediated securities 48 partnerships 49 non-residents income tax relief 50 collection of tax from uk representatives 51 investment manager exemptions 52 investment management fees & carried interest 53 loans from non-resident companies 54 transactions in securities 55 rates of income tax/cgt 56 personal allowances 57 national insurance contributions 58 chargeable gains 59 uk property held by non-residents 60 private residence relief 61 gains of non-resident settlor-interested trusts: s.86 62 capital payments from non-resident trusts: s.87 63 borrowing by non-resident trust: sch 4b 64 protected trusts 65 sub-funds 66 gains of non-resident companies 67 capital losses 68 foreign currency issues 69 unremittable assets 70 double taxation arrangements: introduction 71 dta anti-abuse rules 72 foreign tax credit relief 73 eu law and uk taxation 74 excluded property: definition 75 excluded property exemptions 76 wills and iovs 77 reservation of benefit 78 inter-trust transfers: iht 79 iht deduction for debts 80 iht double taxation treaties: introduction 81 iht dtas: india, pakistan, italy, france 82 iht dta: netherlands 83 iht dta: switzerland 84 iht dta: usa 85 foreign iht credit relief 86 non-dom/non-resident spouse 87 family home and chattels: benefit in kind charges 88 iht residential property code 89 pre-owned assets 90 joint accounts 91 ated taxes 92 estates of deceased persons: cgt 93 estates of deceased persons: income tax 94 who is the settlor? 95 trusts with two or more settlors 96 situs of assets for iht 97 situs of assets for cgt 98 foreign entities 99 hybrid entities 100 control connected close and related expressions 101 permanent establishment and branch/agency 102 reporting and compliance 103 claims 104 reporting and compliance: iht 105 reporting beneficial owners 106 disclosure of offshore trusts 107 requirement to correct 108 criminal law and professional conduct appendices appendix 1a: words of dispute appendix 1: common legal expressions appendix 2: family terminology appendix 3: consideration, arm's length/full value appendix 4: associated operations: iht appendix 5: deeming provisions appendix 6: what do we mean by "real" appendix 7: parliamentarians appendix 8: visiting forces appendix 9: how to improve residence and domicile taxation appendix 10: reform of offshore anti-avoidance rules appendix 11: uk arrival or departure: tax checklist appendix 12: the wisdom of parliament new 2019/20 edition now out the 2019/20 printed edition of taxation of non-residents and foreign domiciliaries is now out. the online edition contains the text of that edition with some subsequent updates . how to login most of this site requires you to login . to obtain a login licence:  every copy of the printed book has a 3 week trial licence (see inside back cover of volume 1) to order copies of the book email the publishers or go to the publishers' website .  you may purchase a single or multiple user licence: to obtain these contact the publishers .  without logging in, you can access: chap 1 foreign domicile: tax policy ; chap 2 tax avoidance . you enter this site once you have registered and logged in by clicking on the index on the left, or you can search the text. you need to register with the password for the current edition. registration for an earlier edition is not valid. comments please users can also contribute to the text and if you can add anything, or spot anything that needs to be corrected, please do! a copy of the next edition of the book will be given to the user who makes the most edits. user contributions are reviewed by ross birkbeck . if you want further advice if you do not find the answer to your question here, or if you want advice on which you can legally rely, you may instruct james kessler qc to advise. see how to instruct james kessler qc . archive editions there are archive editions for years since 2003/04. these will occasionally be useful to investigate the tax position in earlier years, but the current edition will generally be the best starting point, as that has been written in the light of current hmrc guidance, and further thought and research. contact if you have technical problems, or problems logging in, click here to contact james kessler qc click here to contact ross birkbeck, who reviews online contributions, click here for multiple user licences, or to install on a firm's intranet, contact the publishers . technical notes tfd online is in technical terms a wiki on the lines of wikipedia , but only registered users can edit the text. site hosting and management by highwire retrieved from " https://www.foreigndomiciliaries.co.uk/index.php?title=main_page&oldid=13269 " navigation menu views page discussion view source history personal tools create account log in search navigation main page help tools what links here related changes special pages printable version permanent link page information this page was last modified on 19 july 2019, at 10:45. terms & conditions about

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https://www.foreigndomiciliaries.co.uk/index.php/Main_Page//index.php/excluded_property:_definition
https://www.foreigndomiciliaries.co.uk/index.php/Main_Page//index.php/appendix_12:_the_wisdom_of_parliament
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https://www.foreigndomiciliaries.co.uk/index.php/Main_Page//index.php/rates_of_income_tax/cgt
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