International succession

Our fictional client Charles has lived in the Bahamas since 2005 when he left the UK permanently giving up his domicile of origin here. He is divorced and made his permanent home in the capital Nassau in the latter part of 2005.

The Bahamas has no capital gains tax income tax or inheritance tax and has no double tax treaties with other countries. Charles is the majority shareholder in a UK unlisted company Sports Ink Ltd which is a sports promotions business. He relocated to the Bahamas to be closer to the US where his main promotions were arranged on a pay-per-view basis.

Charles receives a small director’s fee and dividend each year; in 2019-20 these were £8 632 and £41 368 respectively. His advisers make a reconciliation calculation each year under ITA 2007 s 811 and compute that...