Are you domiciled in the UK?
What does domicile mean? Your domicile status is decided under general law, which means it must be interpreted according to previous rulings of the courts. There are many things which affect your domicile. Types of domicile There are 3 types of domicile: 1. Domicile of origin You normally acquire a domicile of origin from your […]
IR35 – increased scrutiny from HMRC
IR35 – what is it? The Intermediaries Legislation, IR35, deals with disguised remuneration or “off payroll” work. Its core aim is to stop people setting up personal service companies to avoid paying income tax and NI (and rather pay tax on dividends) even though they are essentially an employee. This has been an area that […]
EMI share option schemes – now more or less attractive?
What is EMI? The Enterprise Management Incentive (EMI) is a tax-advantaged share option scheme designed for smaller companies. It not only helps to retain key staff, but also provides tax benefits for both the employer and employee – please see our article for full details here. One of the key tax advantages is that no […]
UK tax relief for overseas tax paid
Tax Relief can be applied in the UK where an individual or company is required to pay tax on the same income in another country. How is UK tax relief achieved? In the UK, this can be achieved in two ways: Relief under Double Taxation Agreements – this is where the Double Tax Treaty between […]
Non-Resident Capital Gains Tax on UK Commercial Property – what can be done?
From 6 April 2019, non-residents will be subject to UK Capital Gains Tax on the sale of UK commercial property. This came in to effect for UK residential property from 6 April 2015. The new regime also extends to indirect disposals through sales of interests in property-rich companies, property unit trusts and partnerships. A non-resident […]
Can overseas companies qualify for EIS/SEIS?
Very broadly, EIS/SEIS are approved UK tax advantaged schemes, which give investors a tax break for investing in early stage companies. Please see details in our article on SEIS/EIS investment here. These schemes have encouraged angels to invest around £1.5bn annually. It is a common misconception that only UK companies can qualify for SEIS and […]
Do you have a Permanent Establishment in the UK?
What is a UK Permanent Establishment? A Permanent Establishment (“PE”) is created in a situation where a business is mainly based/trading in an overseas territory, but it has a taxable presence in the UK. Full details as to what is classified as a taxable presence are detailed below. For non-resident companies, the liability to UK […]
Investing in UK property through an LLP
There are many ways to invest in UK property – the most common ways to do so are as an individual or via a company. One other way to do so is through an LLP. What is an LLP? An LLP is a type of partnership. It is generally a preferred vehicle as it […]
UK Transfer Pricing
What is transfer pricing? Transfer pricing is the pricing of the provision of goods, assets and services between connected parties. The test to determine whether two or more persons are connected for the purposes of UK transfer pricing legislation looks at “Participation in the management, control or capital”. This generally means greater than a 50% […]
