BVI Resident (UK Citizen) - Money Transfers to UK

[BVIResidentBritishCitizen]

I am a British citizen but a BVI resident. I will probably be employed here in the BVI for 2 years and I understand that as there is a double tax treaty, I can send my BVI income to my UK account with no further taxation in the UK. Most of my BVI income is wired to an IOM trading account. When does this need to be wired to my UK account (i.e. whilst I am still living here) and is there any risk of UK tax either way?

[maths]

The issue is whether you are resident in the UK for UK tax purposes.

If not, then your salary earned for duties performed abroad is not subject to UK income tax and the monies can be transferred at any time to the UK without charge.

If you are UK resident, UK income tax is payable on your salary; again subsequent transfer of monies to the UK precipitates no further UK tax charge.

[BVIResidentBritishCitizen]

Thanks.

I am no longer a UK resident for tax purposes.

Is there any benefit in filing tax returns in the UK whilst I am in the BVI (to establish a paper trail of my non-residency and lack of UK taxable income)?

So if I moved back to the UK in a year and in 10 years time I transfer my offshore savings (plus interest/growth) to my UK bank account, what would be taxable (just the interest/growth?) at that time? Is there any benefit transfering the money back to the UK before I return?

[maths]

So if I moved back to the UK in a year and in 10 years time I transfer my offshore savings (plus interest/growth) to my UK bank account, what would be taxable (just the interest/growth?) at that time? Is there any benefit transfering the money back to the UK before I return?

On moving back to the UK any interest earned on the offshore monies from the date you return would be subject to UK income tax each tax year. Keeping the monies offshore for ten years after you return is of no help (unless you are non-UK domiciled which does not appear to be the case).

No, there is no point in filing UK Tax Return as you suggest.

[BVIResidentBritishCitizen]

Thanks.

Just to confirm: if I achieve say 50% growth in my IOM trading account whilst living in the BVI, that growth can never be taxed in the UK after I move back there because I achieved that growth whilst I was a non-res and so it falls under the BVI/UK double taxation treaty?

[maths]

If you have remained UK resident whilst in BVI, any income and capital gains subject to UK tax

If you have become non-UK resident, when you return to the UK and become resident again any income credited to your offshore account thereafter is subject to income tax. Similarly any capital gains you may make thereafter (eg sell an asset) are also subject to CGT.

EG. Purchse assest whilst in BVI 100. Sell after becoming UK resident 150. CGT on capital gain of 50 thus in effect paying UK CGT on some part of growth which occurred whilst you were in BVI.

I assume you are not a professional dealer in shares etc.

[BVIResidentBritishCitizen]

Thanks.

Yes, I am a currently UK non-res (and BVI resident) for tax purposes.

To clarify:

If I end up with 100 in my IOM savings/trading account the day before I return to the UK, what should I do with the 100, if I ultimately want it in a UK bank account? The 100 will be a combination of savings from salary, interest and growth from investments (some of the money is invested in mutual funds) and I would like to get it back into the UK with as little additional taxation as possible (there's an 8% payroll tax in the BVI).

Breaking down the options:

1. If I transfer the 100 to my UK bank account whilst still a BVI res and UK non-res, will the whole 100 be treated as income whilst earned in the BVI and as such be non-taxable in the UK under the double taxation treaty?
2. If I transfer the 100 to my UK bank account once I am a UK res again, what is taxed?
3. Would it be better to simply scrap the offshore trading/savings account and drip feed savings into my UK savings/trading accounts each month whilst UK non-res?
4. What if I keep the 100 in my IOM account permanently and let it grow. I assume that if I never bring this money onshore (e.g. use it as a deposit on an offshore mortgage to buy a UK property in the future) then only the interest earned (not capital growth) will ever be taxed in the UK?

[maths]

1. If I transfer the 100 to my UK bank account whilst still a BVI res and UK non-res, will the whole 100 be treated as income whilst earned in the BVI and as such be non-taxable in the UK under the double taxation treaty?

There is no double tax treaty. None of the 100 will be subject to UK tax.

2. If I transfer the 100 to my UK bank account once I am a UK res again, what is taxed?

No part of it.

3. Would it be better to simply scrap the offshore trading/savings account and drip feed savings into my UK savings/trading accounts each month whilst UK non-res?

Irrelevant.

4. What if I keep the 100 in my IOM account permanently and let it grow. I assume that if I never bring this money onshore (e.g. use it as a deposit on an offshore mortgage to buy a UK property in the future) then only the interest earned (not capital growth) will ever be taxed in the UK?

Whether brought on shore or not is irrelevant as I have already said.
Interest thereon will be taxable.
Not sure about your ref to "capital growth"; monies in the bank account cannot suffer capital growth. Any investments you hold (eg shares) sold after you return to the UK will result in any capital gain being subject to CGT.

[BVIResidentBritishCitizen]

Incorrect. See: http://www.hmrc.gov.uk/international/british-virgin-islands.htm

How does this impact your terse analysis?

[maths]

I look forward to your confirmation of the date the double tax agreement to which you refer entered into force in the UK and BVI.