I sat down with an advisor the other day and he told me I would be hit for double taxation on the full amount of my estate should I pass away.
I`m a Brit living in Japan for 13 years and will probably remain here. But I will not give up my UK domicility.I have been told the Japanese tax man will take his portion of whatever I have globally as well as the UK tax man.assuming I had a million scattered in Japan and offshore.Is he right in saying that both sides would tax me on the full million whether it is, and not whatever portion was left after the other had got their hands on it?
Any confirmation would be greatly appreciated.
Robert..
Double taxation...
4 posts • Page 1 of 1
by maths on Fri Aug 26, 2005 2:12 pm
I haven't had time to check, but don't believe there is an iht double tax agreement between UK and Japan. It is therefore necessary to rely on any relief for double tax under the UK's unilateral provisions.
In principle, however, some relief is available; the measure of relief depending upon, inter alia,location of assets and amount of tax levied.
In principle, however, some relief is available; the measure of relief depending upon, inter alia,location of assets and amount of tax levied.
- maths
- Posts: 4488
- Joined: Wed Aug 06, 2008 3:25 pm
by TaxationWeb@BritishA on Sat Aug 27, 2005 5:55 am
Assuming maths is right, then you are subject to double taxation, but it may not be as bad as it seems.
You might not want to give up your UK domicile, but perhaps you should speak with a dual qualified UK/Japan adviser to make sure that this is advisable. Domicile is not citizenship; if you give up your domicile you still remain a UK citizen. You need to weigh the pros and cons for both countries.
Assuming it is advisable to remain UK domiciled, then the UK will tax your worldwide income, but give a tax break for any foreign taxes paid. Japan, if it also deems you domiciled, will give you a tax break for any foreign taxes paid.
Thus, UK gives a tax break for Japaneses IH taxes paid on Japanese assets, and Japan gives a tax break for UK IH taxes on UK assets. The double tax arises on assets held in countries that have no tax, where both UK and Japan will tax the asset and there will be no corresponding foreign tax to reduce the domiciled country taxes.
You might not want to give up your UK domicile, but perhaps you should speak with a dual qualified UK/Japan adviser to make sure that this is advisable. Domicile is not citizenship; if you give up your domicile you still remain a UK citizen. You need to weigh the pros and cons for both countries.
Assuming it is advisable to remain UK domiciled, then the UK will tax your worldwide income, but give a tax break for any foreign taxes paid. Japan, if it also deems you domiciled, will give you a tax break for any foreign taxes paid.
Thus, UK gives a tax break for Japaneses IH taxes paid on Japanese assets, and Japan gives a tax break for UK IH taxes on UK assets. The double tax arises on assets held in countries that have no tax, where both UK and Japan will tax the asset and there will be no corresponding foreign tax to reduce the domiciled country taxes.
- TaxationWeb@BritishA
- Posts: 326
- Joined: Wed Aug 06, 2008 3:14 pm
4 posts • Page 1 of 1
TaxationWeb Limited (Registered in England No. 4571386), 6 Coleby Avenue, Peel Hall, Manchester, M22 5HH, United Kingdom
Information which you supply whilst using this website may be held in our computer records and may be used to send you information which we think might be of interest to you. If you do not want your information to be used for such purposes please write to us at: 6 Coleby Avenue, Peel Hall, Manchester M22 5HH, UK, or email us
Website by Dorifor Internet Marketing | Powered by phpBB
Dorifor Tax Group - our portfolio of tax sites:
