Welcome to the June 2020 edition of International Client.
We would draw readers’ attention to the fact that international corporates (including non-resident landlords from 6 April 2020) may wish to revisit their transfer pricing policies in the light of Covid-19, and adjustments could potentially alleviate the tax position. Your usual Saffery Champness contact, or Dawn Ross, who will be pleased to provide advice if required.
It is also noteworthy that HM Revenue & Customs (HMRC) has published guidance on the impact of Covid-19 on UK residency status. When counting the number of days an individual is present in the UK for the purposes of the relevant residency tests, days of presence due to exceptional circumstances may, in certain circumstances, be disregarded. HMRC has confirmed that individuals unable to leave the UK owing to travel restrictions and government guidance may be able to treat the circumstance as ‘exceptional’, but each case will need to be considered on its facts.
In this issue, we also take a look at Ireland’s tax and visa regime for foreign nationals considering relocating there. Read more.
We also discuss the latest EU directive on administrative cooperation (DAC 6), and the different structures available for holding real estate. Read more.
Finally, I would remind readers of the following recent changes:
- From 6 April 2020, individuals and trusts disposing of UK residential property will have just 30 days to file a capital gains tax return and pay any tax due.
- Collective investment schemes holding UK property assets have until 1 October 2020 to make a transparency election for capital gains tax purposes.
- From April 2020 the Structures and Buildings Allowance (SBA) rate has increased from 2% to 3%.
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