REMITTANCE

The Temporary Repatriation Facility could create significant tax savings for some. Alice Pearson (Mercer & Hole) highlights some practical considerations and areas of complexity.

Dominic Lawrance

Sophie Dworetzsky

They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) comment on the end of the remittance basis, the ‘absolute mess’ that is the double remittance situation and a potentially worrying change in HMRC’s view on the taxation of capital payments in ancillary relief on divorce.

Peter Vaines

Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...

Henry Lowe

Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment now that the non-dom regime has been abolished.

Kazia Gagg

Edward Reed

Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for private clients under the new Labour government and comment on a number of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.

Sam Epstein

Edward Reed

Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of ‘service’ under the remittance basis rules are reviewed by Edward Reed and Sam Epstein (Macfarlanes).

Debt indemnity arising from share sale did not give rise to a remittance to the UK

Catrin Harrison

Dominic Lawrance

Four key factors determine whether investments are suitable for remittance basis users from a UK tax perspective, write Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys).

Catrin Harrison

Dominic Lawrance

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine possible planning opportunities to safeguard a remittance basis user’s existing clean capital reserves.