Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) examine, among other things, some of the recent clarifications and outstanding concerns regarding both the non-dom reforms and the proposed changes to agriculture and business property reliefs.
Finance Bill 2024/25
Changes to the Finance Bill were published in the amendment paper on 25 February (‘the amendments’).
The good news is that the amendments have resolved the issue identified in last month’s private client review (Tax Journal 21 February 2025) that there was a possibility of taxable remittances arising as a result of transfers to non-UK bank accounts.
The bad news is that there remains a serious concern about the retroactive extension of the concept of a remittance. Under the current legislation (ITA 2007 s 809P(12)) there can be no ‘double remittance’ of foreign income and gains (FIG). Once FIG have been remitted they cannot be taxably remitted again....
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Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) examine, among other things, some of the recent clarifications and outstanding concerns regarding both the non-dom reforms and the proposed changes to agriculture and business property reliefs.
Finance Bill 2024/25
Changes to the Finance Bill were published in the amendment paper on 25 February (‘the amendments’).
The good news is that the amendments have resolved the issue identified in last month’s private client review (Tax Journal 21 February 2025) that there was a possibility of taxable remittances arising as a result of transfers to non-UK bank accounts.
The bad news is that there remains a serious concern about the retroactive extension of the concept of a remittance. Under the current legislation (ITA 2007 s 809P(12)) there can be no ‘double remittance’ of foreign income and gains (FIG). Once FIG have been remitted they cannot be taxably remitted again....
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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