DIXCART
INTERNATIONALPeter Robertson
28th January 2018
• Company Incorporation
• Establishment and Management of International Structures
• Accounting and legal work
• Family Office Services
• Private and corporate tax
• Trusts and Foundations
• Citizen/Residence Services for Individuals
Private Wealth & Corporate Advisors
The United Kingdom
UK Example
• Anil Is an Indian Citizen
• He is married and has two minor children
• He would like to move to London
• He may well start a business
What are his options?
Citizenship & Residence by Investment
Tier 1 Investor
• Applies to main applicant and his/her family
• Invest £2 million – leave to remain after 5 years
• Invest £5 million – leave to remain after 3 years
• Invest £10 million – leave to remain after 2 years
• May only spend 180 days outside the UK
Citizenship & Residence by Investment
Types of Investment
• UK Government Bonds
• Share capital in UK registered companies
• Loan capital in UK registered companies
Note investor must be beneficial owner of the funds used and
sources must be acceptable
Citizenship & Residence by Investment
Visa and Permanent Leave to Remain
• Initial visa issued for 3 years and 4 months
• Then renewed for 2 years
• Only renewed if you have complied with all conditions, including no more than
180 days’ absence per year
• After 5 years you can apply for permanent leave to remain
Citizenship & Residence by Investment
Entrepreneur’s Visa
• Requirements:
• English language capability
• £200,000 to invest – or
• £50,000 from one of –
• Venture capital company FSA registered
• UK Entrepreneurial Seed Funding organisation
• UK Government department
• Jobs
Citizenship & Residence by Investment
Entrepreneur’s Visa – Must be Genuine
• Must demonstrate intentions are genuine
• A business plan
• Experience and education of the investor
• Show that the investment funds are available
• Market research
Citizenship & Residence by Investment
• How will Anil be taxed in the UK? Remittance basis?
• Residence?
• Domicile?
Citizenship & Residence by Investment
Non-Resident• 16 for a leaver/46 days for an arrive
• Work abroad, present < 91 days, work in UK < 31 days
Resident• 183 days
• UK Home & no overseas home
• Work full-time
Statutory Residence Test
Connecting Factors
• Resident family
• Substantive employment
• Accessible accommodation
• 91 days presence in either of previous 2 years
• In UK more than anywhere else (leaver only)
Statutory Residence Test
• A person takes as his domicile of origin from the domicile of his father at the
time of his birth if his parents are married
• If not he takes the domicile of his mother
• Person can only acquire a new independent domicile on attaining age 16 as
indicated on the next slide
Domicile
• A person can only change a domicile by:
(a) moving to another jurisdiction
(b) with the intention of remaining there permanently or indefinitely
• Onus of proof
• Deemed domicile for income tax, capital gains tax & inheritance tax –
resident in the UK in 15 out of the last 20 years
Changing Domicile
• Taxed only on UK source income and gains and on foreign income and
gains only in so far as they are remitted to the UK
• Remittance basis charge:
• No charge in the first seven tax years of residence
• £30,000 when tax resident 7 out of 9 years
• £60,000 when tax resident 12 out of 14 years
• Loss of personal allowance
Remittance Basis of Taxation
Pre-arrival Planning
• If possible, realise gains to get new base cost
• Segregate original capital
• Beware of mixed funds
• Keep as much outside as possible
• Consider a trust
Citizenship & Residence by Investment
Anil’s Case
• Pay full tax on UK source income, includes income from £2m
investment
• All other income free from UK tax if not remitted- this applies for up
to 15 years if the remittance basis is used
• No charge for remittance basis for 7 years
• Non UK assets free from UK inheritance tax for 15 years
Citizenship & Residence by Investment
The same visa rules apply to the Isle of Man and Guernsey
• Both islands have:
• No capital gains tax
• No inheritance tax
• No wealth tax
• Low income tax
• IOM 20% capped at £150,000
• Guernsey- pay 20% on GSY income plus cap on tax on non-GSY
income of £110,000 OR cap tax on worldwide income of £220,000
UK: Too Taxing?
Brexit
• 23 June 2016 to 29 March 2019 (11am!)
• Immigration? Could be opportunities
• VAT
• Alternatives for individuals:
• Portugal (Eur500,000)
• Cyprus (Eur2m)
• Malta (Eur1.2m)
• Quick incorporation
• 17% corporate tax
• Tax neutral investment company:
• Brexit/DTAs
• R&D Tax credits
• n.b. Tax policy and prevention of evasion
• BUT:
• Banking
• VAT
Corporate position and tax
THANK YOU
www.dixcart.
com