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Autumn Budget 2024: Non-UK domiciled individuals and Offshore Trust

Changes to the taxation of non-UK domiciled individuals  Abolition of the “remittance basis” and the new “FIG” regime - Income tax and Capital gains tax (CGT) Starting from 6 April 2025, the current “Remittance Basis” regime, available for non-doms, will be abolished and replaced by a new “Residence-based” regime, known as the Foreign Income and Gains (FIG) regime. The concept of domicile will no longer be relevant to UK taxation, and as a general rule, ...

Non-dom status and offshore trust after UK General Election

"Change begins now” said Labour’s leader Keir Starmer, winner in the UK general election. The new Labour government is set to implement in the coming months a series of fiscal policies to take effect from 6 April 2025 with the aim of rebalancing the budget deficit and encouraging economic growth, including: Abolition of the resident non-domicile status: “non-dom" status refers to a person's tax status and describes a UK resident whose permanent home (“domicil...

Tax Residence of Companies and Entities (Country Italy) Place of effective management and ordinary management new connection criteria with the territory of the State

The current wording of article 73, paragraph 3 of the Italian Tax Consolidated Act (hereinafter TUIR) (tax residence of companies and entities), as amended by Legislative Decree 209/2023 implementing the tax reform on international taxation, establishes that companies and entities are tax resident in Italy if they have in the territory of the State, for the greater part of the tax period:  (a) their registered office; or (b) the place of effective manageme...

UK residential Property: annual tax on enveloped dwellings (ATED) implications

Overview Most residential properties (dwellings) in the UK are owned directly by individuals. But in some cases a dwelling may be owned by a company or a partnership or other collective investment vehicle, whether UK resident or non-resident. In these circumstances the UK dwelling is said to be “enveloped” because the ownership sits within a corporate “wrapper” or “envelope”. Chargeable Persons The Annual Tax on Enveloped Dwellings (ATED) is a tax charged on “...

Spring Budget 2024 [Source: HM Revenue & Customs, Spring Budget 2024, 06/03/2024]

On 6 March 2024 the Chancellor of the Exchequer, the Rt Hon Jeremy Hunt MP, made his Spring Budget speech and set out the government’s plans to bring forward a series of reforms and measures to simplify and make the tax system fairer and supports public finances.  Key tax measures announced are detailed below. Information on all the measures announced, including the annual uprating of duties and rates, can be found in the Spring Budget 2024 and i...

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