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Taxation of Non-Residents and Foreign Domiciliaries 2024-2025 23rd ed: ONLINE ACCESS

Taxation of Non-Residents and Foreign Domiciliaries 2024-2025 23rd ed: ONLINE ACCESS

  • 作者:
  • 出版商: Key Haven Publications PLC
  • ISBN: 9781901614923
  • Previous Edition ISBN: 9781901614909
  • 出版时间 May 2024
  • 规格: Online
  • 适应领域: U.K. ? 免责申明:
    Countri(es) stated herein are used as reference only
¥6,438.53
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  • 描述 
  • 大纲 
  • 详细

    Taxation of Non-Residents and Foreign Domiciliaries is the bible of those giving tax advice to foreign clients living in the UK.

    Published in 8 volumes, the annual edition 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
    • Other topics arising in this context, including tax avoidence and disclosure and compliance

     

  • Non-dom policy & avoidance
    1 Foreign Domicile: Tax Policy
    2 Tax Avoidance
    3 TAARs

    Domicile & residence
    4 Domicile
    5 Deemed Domicile
    6 Residence of Individuals
    7 Residence of Trustees
    8 Residence of Companies
    9 Treaty-Residence
    10 Split Years
    11 Temporary Non-residence
    12 Exit Taxes
    13 UK Arrival or Departure: Tax Checklist

    Income tax: Principles & remittance basis
    14 Income and its Categorisation
    15 Source/RFI/Territorial Principles
    16 Income Recognition: Receive/Entitled/Arise/Paid
    17 The Remittance Basis
    18 The Meaning of Remittance
    19 Remittance Reliefs
    20 Mixed Funds

    Income by category
    21 Trading Income
    22 Trading in Land
    23 Performers
    24 Property Income
    25 Deduction of Interest from Property Income
    26 Interest Income
    27 Exempt Interest of Non-Residents
    28 Accrued Income Profits
    29 Deeply Discounted Securities
    30 Dividend Income
    31 Annual Payments
    32 Intellectual Property Income
    33 Misc Sweep-Up Income
    34 Employment Income
    35 Travel Expenses: Employment Income
    36 PAYE
    37 Employment Income: DT Relief
    38 Pension and Annuity Income
    39 Benefit in Kind: Family Home and Chattels
    40 Benefit in Kind: Loans from Non-Resident Companies

    IT: general
    41 Discretionary Trusts: Income Tax
    42 IIP Trusts: Income Tax
    43 Rates of Income Tax/CGT/CT
    44 Personal Allowances
    45 Non-Residents Income Tax Relief
    46 National Insurance Contributions

    IT avoidance codes
    47 Settlor-Interested Trust Code
    48 Transfer of Assets Abroad: Introduction
    49 Transfer of Assets Abroad: Transferors
    50 Transfer of Assets Abroad: Benefits
    51 Transfer of Assets Abroad: Relief from Overlapping Charges
    52 Transfer of Assets Abroad: Motive Defence
    53 Profit Fragmentation
    54 Transfer of Income Streams
    55 Transactions in Securities

    Capital Gains Tax
    56 Chargeable Gains
    57 UK Property held by Non-residents
    58 Reorganisations
    59 Residential Property: CGT
    60 Gains of Non-Resident Settlor-Interested Trusts: s.86
    61 Capital Payments from Non-Resident Trusts: s.87 code
    62 Borrowing by Non-resident Trusts: Sch 4B
    63 Sub-Funds
    64 Gains of Non-Resident Companies
    65 Capital Losses

    Funds
    66 Funds: Terms & concepts
    67 Offshore Income Gains
    68 Income from Offshore Funds
    69 Unit Trusts
    70 Life Policies and Contracts
    71 Intermediated Securities
    72 Investment Manager Exemptions
    73 Investment Management Fees & Carried Interest

    Inheritance Tax
    74 IHT Terms and Concepts
    75 Excluded Property: Definition
    76 Excluded Property Exemptions
    77 Wills and IOVs
    78 Reservation of Benefit
    79 Inter-Trust Transfers: IHT
    80 IHT Deduction for Debts
    81 IHT Close-company Code
    82 IHT Residential Property Code
    83 Pre-Owned Assets
    84 Pension Schemes and IHT

    Entities
    85 Partnerships
    86 Partnership income: Attribution
    87 Settlement, Bare Trust, and Associated Terminology
    88 Estates of Deceased Persons: CGT
    89 Estates of Deceased Persons: Income Tax
    90 Foreign Entities
    91 Hybrid Entities

    Topics affecting more than one tax
    92 Protected Trusts
    93 Non-Dom/Non-Resident Spouse
    94 Joint Accounts
    95 Foreign Currency Issues
    96 Cryptoassets
    97 Unremittable Assets
    98 ATED and SDLT
    99 Who is the Settlor?
    100 Multiple Settlors
    101 Statutory Tax Indemnities
    102 Situs of Assets for IHT
    103 Situs of Assets for CGT
    104 Control, Connected, Close and Related Expressions
    105 Participation & % interest tests
    106 Permanent Establishment and Branch/Agency

    Double Taxation Agreements: IT/CGT
    107 Double Taxation Arrangements: Introduction
    108 DTA Anti-Abuse Rules
    109 Third Party Relief/Savings Clause
    110 Limitation on Benefits
    111 Credit for Foreign Tax
    112 Non-discrimination
    113 Mutual agreement proceedure

    Double Taxation Agreements: IHT
    114 IHT Double Taxation Treaties: Introduction
    115 IHT DTAs: India, Pakistan, Italy, France
    116 IHT DTA: Netherlands
    117 IHT DTA: South Africa
    118 IHT DTA: Switzerland
    119 IHT DTA: USA
    120 Credit for Foreign IHT

    Administration
    121 Reporting and Compliance
    122 Tax Return Filing Position
    123 Claims
    124 Collection of IT/CGT from UK Representatives
    125 Reporting and Compliance: IHT
    126 Penalties
    127 Failure to Prevent Tax Evasion
    128 Reporting Offshore Trusts
    129 International Movement of Capital: Reports

    CRS & Money Laundering
    130 Common Reporting Standard
    131 Trust Registration (TRS)
    132 Customer Due Diligence
    133 Money Laundering: POCA

    Appendices:

    Words & Concepts
    1 Words of Dispute
    2 Common Legal Expressions
    3 Family Terminology
    4 Consideration/Arm's Length/Full Value
    5 Commercial/View to Profit
    6 Beneficial Ownership/Entitlement
    7 What do we mean by “Real”?

    Statutory construction
    8 Deeming Provisions
    9 Purpose of Statute

    Special taxpayers
    10 Parliamentarians
    11 Visiting Forces
    12 Students and Teachers

    Tax reform
    13 How to Improve Residence and Domicile Taxation
    14 Reform of Offshore Anti-Avoidance Law
    15 Citizenship-based Taxation
    16 The Wisdom of Parliament

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