Residence and Domicile
- Residence – old rules and occasions where they are still important
- Residence – new rules, an explanation of the SRT
- Domicile – old rules and their relevance
- Domicile – rule changes
Opportunities
Residence
- Maintaining non-residence under the day counting regime
- Overseas work day relief
- Remaining CGT exemptions for non-residents
- Treaty residence – how it differs from domestic residence
- Use of personal allowance and lower rate tax bands
- Years of arrival and departure
- Dual residence
- Exemption with progression v tax credits
- The earnings basis, receipts basis, bonuses and share options
- Termination payments, the traps and opportunities
Domicile
- First seven years
- Next eight years
- De minimis limits
- Pre-arrival planning
- Use of offshore trusts
- Children’s tax position
- IHT and the non UK-domiciled spouse
- Obtaining tax credits for the RBC
We could then end with potentially three case studies:
- a non-UK domiciled individual who is sent on a long term assignment to the UK,
- non UK-domiciled individual who comes to the UK for an indefinite period who is of independent means
- a UK-domiciled individual who goes abroad for an indefinite period