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CAROLYN STEPPLER examines practical considerations when taking advantage of the new business investment relief for non-domiciled individuals
KEY POINTS
- The new business investment relief for non-doms in ITA 2007 Part 14.
- Investment must be by subscription for shares or loan.
- The criteria of a qualifying company.
- The importance of monitoring the company’s circumstances.
- The consequences of qualification ceasing.
As Bob Monkhouse said “When opportunity comes your way don’t knock it.” But how big an opportunity does the new business investment relief present for those who are non-domiciled and what are the practical considerations in accessing the relief?
When the government began consulting about a new investment relief for non-UK domiciled individuals back in June 2011 it seemed a welcome opportunity for these individuals (as well as offshore structures) to use overseas income and gains to invest in the UK without a tax charge.
Although the...
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