Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts
Tax consolidation: non-resident intermediary companies
Priya Dutta answers a query on the tax residency of employees seconded to overseas offices and undertaking training in the UK
Group relief when the link company is non-UK resident
Jackie Wheaton answers a query on whether interest has a UK source, reviewing the key issues following Perrin v HMRC
Peter Stevens summarises the government’s proposals for charging tax on capital gains made by non-residents from disposals of UK residential property
Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed
Peter Vaines comments on the operation of CGT on non-residents and ATED
Non-domiciled taxpayers are paying record amounts of tax on income that they generate in the UK, according to figures obtained by the law firm Pinsent Masons.
The monthly round-up by Chris Morgan, with news from the OECD’s BEPS project, two CJEU cases and the latest from France, India and Chile