Residence & domicile

A company is resident in both the UK and in Brazil and wonders whether loss relief will be available as group relief in the UK and by carry forward in Brazil. It seems to be that loss relief can be given in both countries but the operation of double taxation relief will mean that relief is only effectively given once

Is a gain on foreign currency made when funds are transferred abroad for extending and maintaining a property a chargeable gain?

A non-UK income tax domiciled client using the remittance basis for 2008/09 has offshore losses for that year. Can these be carried forward to 2009/10 when the arising basis will apply and there are UK and offshore gains?

A UK-domiciled husband is married to a woman who was born in Denmark and may return there should her husband pre-decease her. The wife’s domicile has never been determined

A client in the emergency services is paid an annual accommodation allowance as he is required to live within 15 minutes of his base. The allowance is paid monthly and is taxed as part of his salary

RORY MULLAN suggests that when moving within the EU, UK nationals resident in this country may be at a disadvantage

Enquiry only when significant risk of loss of UK tax

PDF available to download

VICTOR CLARENDON warns that tax jurisdictions are looking for substance and not just the figment of a tax planner’s imagination

Proceedings expected early next year

A UK taxpayer has become non-UK resident and intends to transfer stocks out of an ISA. The tax implications of such a transfer are considered

Re the Trevor Smallwood Trust; Smallwood and another v CRC, Court of Appeal