International Client – January 2020

6 Jan 2020

aeroplane shadow on beach

Welcome to the January 2020 edition of International Client.

Our first article looks at the OECD’s Pillar 1 discussion draft, which outlines a partial solution to the challenges associated with taxation of the digital economy and the determination of taxable profits.

We discuss two recent cases, and a change in HM Revenue & Customs’ guidance, which will have an impact on the UK tax position of offshore trust and company structures, particularly those in the Channel Islands and Isle of Man.

We consider the tax position for non-resident landlords who rent property in the UK, and how the pending switch from income tax to corporation tax will affect them.

We also look at how an individual’s domicile is determined, and why domicile under general law remains important even if an individual is treated as UK domiciled for tax purposes.

Finally, with the Conservatives winning a large majority in the recent General Election, the UK’s departure from the European Union is now a certainty, although the contents of any future free trade agreement remain unclear. The government can be expected to enact the policies outlined in the Conservative Party Manifesto and we have highlighted some of the key tax aspects in the In Brief section.

Should you wish to discuss any of the issues raised in this newsletter, please contact me or your usual Saffery Champness partner.

Ben Melling, Editor

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