- 1. The Remittance Basisfor UK Taxation
- The new remittance rules & how they are working in
practice
2.
- Andrew McKenzie-Smart FCCA CTA
A Seminar for theChartered Institute of Taxation Sussex Area
Branch 3. Introduction What is the remittance basis?
- For UK domiciled individuals
-
- taxed on an arising basis
- For non UK domiciled individuals
-
- taxed on an arising basis for UK income and gains
-
- Can claim for their foreign income and gains to be taxed on a
remittance basis
- Remittance being when the foreign income and gains are remitted
directly or indirectly to the UK
- Changes made to the remittance basis in from 6 thApril
2008
4. Domicile Now UK Dom Non UK Dom born in US UK Dom But NR (?)
Non UK Dom - Father born in Corfu 5. Domicile
- A persons domicile is determined by:
- Their fathers domicile position
- Arises when an individual has been resident in the UK for 17
out of 20 tax years
- Is a Inheritance Tax concept only does not apply to Capital
Gains or Income Tax
Is difficult to change and involves long term lifestyle
decisions 4 6. F oreign Income & Gains
- Profits from trades carried on wholly overseas
- Interest on foreign bank accounts and securities
- Dividends from Non UK Resident Companies
- Rental income from Foreign Property
- Employment income from foreign companieswhere the duties are
undertaken overseas
- Gains on overseas property
- Gains on shareholdings in foreign companies
- Gains on other assets held offshore
3.1/3.1.1/3.12/3.13 7. Remittance Basis Qualifying
Individuals
- UK Resident, Ordinarily Resident & UK domiciled
- UK Resident & domiciled not Ordinarily Resident in UK
- UK resident but not UK domiciled
- UK income and gains always taxed an arising basis
Worldwide income & gains on an arising basis Arising basis
for worldwide gainsRemittance basis available for offshore income
Remittance basis available for offshore income and gains 3.2 8.
Remittance Basis Claim needed?
- Less than 2,000 of unremitted income and gains?
-
- Under 18 at the end of the tax year?
-
- Not resident in the UK for more than 6 out of 9 preceding tax
years
- Or eligible for the s828C exemption? [income if taxed in the UK
would be subject to basic rate tax and they are employed in the
UK]
9. Remittance Basis Claim needed? (2)
- s828C exemption applies to
-
- basic rate UK tax residents but non UK domiciled
-
- If all income were subject to UK tax then no higher rate tax
liability would arise
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- No UK income tax return required
-
- Small amounts of foreign employment income (