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Where Taxpayers and Advisers Meet

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by JSK TAXATION
Fri Nov 14, 2008 1:43 pm
Forum: Income Tax
Topic: Income tax while abroad
Replies: 4
Views: 1143

Re: Income tax while abroad

Daizy, This is a little complicated but I will try to explain as best I can! From information you provide it appears you will be treated as resident and ordinarily resident in the UK throughout. You may be non-UK domiciled but this cannot be determined from the information provided. You do not say w...
by JSK TAXATION
Fri Nov 14, 2008 12:14 pm
Forum: Income Tax
Topic: Income tax while abroad
Replies: 4
Views: 1143

Re: Income tax while abroad

Daizy,

If you can let me have specific dates, I would be able to help. Kindregards.
by JSK TAXATION
Wed Nov 12, 2008 11:21 am
Forum: Income Tax
Topic: Tax Query Non UK resident
Replies: 1
Views: 769

Re: Tax Query Non UK resident

Sideep, The issue really depends on exactly how long your secondment to the UK is for. If it is for less than 183 days, then the income derived will remain taxable in India and you will be treated under HMRC's Appendix 4 procedures in the UK (short term visitors) i.e. not taxable. If the secondment ...
by JSK TAXATION
Fri Nov 07, 2008 10:38 am
Forum: International Tax
Topic: UK company owned by Swiss Holding for tax avoidance purposes
Replies: 5
Views: 1270

Re: UK company owned by Swiss Holding for tax avoidance purposes

Monkey, TN is correct in a general sense i.e. that on the basis that your proposed arrangements are wholly artificial, they are very likely to be caught by the various UK anti-avoidance codes. Nevertheless the type of structure you propose is being used all the time in situations where it is not cau...
by JSK TAXATION
Thu Nov 06, 2008 1:17 pm
Forum: Capital Gains Tax, CGT
Topic: Gifting Shares?
Replies: 2
Views: 902

Re: Gifting Shares?

okevin, As you correctly allude to in the question, where shares or other securities are acquired by reason of employment for less than their market value, then there will normally be a general earnings charge on the money’s worth of those securities, less anything paid for them. The legislation for...
by JSK TAXATION
Thu Nov 06, 2008 10:52 am
Forum: Capital Gains Tax, CGT
Topic: CGT EXEMPT OR UK TRADING
Replies: 4
Views: 1132

Re: CGT EXEMPT OR UK TRADING

vorabj Prima facie there appears to be a combination of trading and investment here since it appears the owners intention changed after the property was built. At this point, HMRC could argue that there was an appropriation from stock to fixed assets i.e. a deemed disposal for trading purposes takin...
by JSK TAXATION
Wed Nov 05, 2008 11:13 am
Forum: Company Taxation
Topic: Sale of Company IP
Replies: 1
Views: 772

Re: Sale of Company IP

Tom 7000

Have you thought about a hive down?

This can be used as something of a 'third way' using group tax reliefs to facilitate the process.

Regards
by JSK TAXATION
Tue Nov 04, 2008 4:27 pm
Forum: Income Tax
Topic: 2007 Offshore disclosure facility
Replies: 3
Views: 864

Re: 2007 Offshore disclosure facility

taxed,

I agree. I would put this to them and if they still insist, ask them for the part of the Act they are currently working under?

All the best....
by JSK TAXATION
Tue Nov 04, 2008 3:42 pm
Forum: Income Tax
Topic: 2007 Offshore disclosure facility
Replies: 3
Views: 864

Re: 2007 Offshore disclosure facility

Taxed, Certainly the profession was led to believe that there was certainty following an acceptance of a disclosure. In fact I remember discussing at some length whether in a situation where a client had overstated tax lost, they would have the right to go back and revisit the position and reclaim t...
by JSK TAXATION
Mon Nov 03, 2008 5:00 pm
Forum: International Tax
Topic: parent subsidary directive
Replies: 1
Views: 739

Re: parent subsidary directive

Del, The EU parent subsidiary directive was originally introduced in 1990 and was designed chiefly to eliminate tax obstacles in the area of profit distributions between groups of companies in the EU. This was achieved by abolishing withholding taxes on payments of dividends between associated compa...

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