I believe the question has been raised a few times over the past 10 years but I have not seen a clear response, so I wanted to ask one more time.
I am UK resident but non-dom. I have an offshore bank & brokerage account in Jersey. Through that offshore broker, I am looking to buy a Dublin-domiciled ETF listed on the London Stock Exchange. The source of the funds is mixed (i.e. not clean capital).
The asset situs (eg for CGT and IHT purposes) is clearly offshore as the share register for the ETF is based in Dublin - so I would not be acquiring any UK property.
Given the above - does the fact that the transaction is effected through the LSE constitute a risk that the transaction is deemed a remittance by HMRC? or is it irrelevant?
I can see a parallel with an offshore-to-offshore payment, where my Jersey bank may well route that through London but because this is purely mechanistical and wholly outside my control - it wouldn't be deemed a remittance (or at least that's my understanding). But here in a way, I would make a choice to acquire the ETF that has a London listing - so there is an element of choice...
Anyhow - expert views welcome...!
- Home
-
Tax News
- Budgets and Autumn Statements
- Income Tax
- Business Tax
- PAYE and Payroll Taxes, National Insurance, NICs
- Company Taxation
- Savings & Investments, Pensions & Retirement
- Capital Gains Tax, CGT
- Property Taxation
- Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
- Tax Investigations & Enquiries
- VAT & Excise Duties
- Stamp Duty, Stamp Duty Land Tax, SDLT
- International Tax
- HMRC Administration, Practice and Methods
- Professionals in Practice & Industry
- General
- TaxationWeb
-
Tax Articles
- Budgets and Autumn Statements
- Income Tax
- Business Tax
- PAYE and Payroll Taxes, National Insurance, NICs
- Company Taxation
- Savings and Investments, Pensions and Retirement
- Capital Gains Tax, CGT
- Property Taxation
- Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
- Tax Investigations & Enquiries
- VAT & Excise Duties
- Stamp Duty, Stamp Duty Land Tax, SDLT
- International Tax
- HMRC Administration, Practice & Methods
- Professionals in Practice & Industry
- General
- Tax Tips
-
Tax Forum
- Income Tax
- Business Tax
- PAYE and Payroll Taxes, National Insurance, NICs
- Company Taxation
- Savings & Investments, Pensions & Retirement
- Capital Gains Tax, CGT
- Property Taxation
- Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
- Tax Investigations and Enquiries
- VAT & Excise Duties
- Stamp Duty, Stamp Duty Land Tax, SDLT
- International Tax
- HMRC Administration, Practices & Methods
- Professionals in Practice & Industry
- General
- Tax Jobs
- Get in Touch