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Recycling of gains to capital (non-domiciled)
What is the procedure when a non-domiciled has an offshore account which contains a mixture of sources, i.e. capital, gains and interest? What is the best way to recycle gains into capital?The current account was established in 1999 before the person (a child) became a UK resident. Only a small part of the funds (€200.000 out of the current balance of €1.5 millions will be converted. The original capital amount was €1 million).
Lottus ,
The UK Inland Revenue view anything coming out of a mixed account as being income.
There are arguments against this,but this might involve fighting a case in the courts. It is a highly controversial and complex area. In my experience it is better to negotiate a way around this issue.
Nobody can advise properly without knowing the full facts.The starting point will be to verify the Domicile status of all involved and possibly to have proof of the original capital sum. Then to look at the history of the account.
There are a number of methods by which it maybe possible to remit monies to avoid any income tax charge and to cleane this account.
This is something that needs proper planning and consideration.
Daniel Feingold
Barrister (NP)
Strategic Tax Planning
Editor UK and International Tax Law section of this website
E-mail: sedrate@easynet.co.uk
Tel:+44 161 720 7244
The UK Inland Revenue view anything coming out of a mixed account as being income.
There are arguments against this,but this might involve fighting a case in the courts. It is a highly controversial and complex area. In my experience it is better to negotiate a way around this issue.
Nobody can advise properly without knowing the full facts.The starting point will be to verify the Domicile status of all involved and possibly to have proof of the original capital sum. Then to look at the history of the account.
There are a number of methods by which it maybe possible to remit monies to avoid any income tax charge and to cleane this account.
This is something that needs proper planning and consideration.
Daniel Feingold
Barrister (NP)
Strategic Tax Planning
Editor UK and International Tax Law section of this website
E-mail: sedrate@easynet.co.uk
Tel:+44 161 720 7244
