DIXCART

INTERNATIONALPeter Robertson

28th January 2018

• Company Incorporation

• Establishment and Management of International Structures

• Accounting and legal work

• Family Office Services

• Private and corporate tax

• Trusts and Foundations

• Citizen/Residence Services for Individuals

Private Wealth & Corporate Advisors

The United Kingdom

UK Example

• Anil Is an Indian Citizen

• He is married and has two minor children

• He would like to move to London

• He may well start a business

What are his options?

Citizenship & Residence by Investment

Tier 1 Investor

• Applies to main applicant and his/her family

• Invest £2 million – leave to remain after 5 years

• Invest £5 million – leave to remain after 3 years

• Invest £10 million – leave to remain after 2 years

• May only spend 180 days outside the UK

Citizenship & Residence by Investment

Types of Investment

• UK Government Bonds

• Share capital in UK registered companies

• Loan capital in UK registered companies

Note investor must be beneficial owner of the funds used and

sources must be acceptable

Citizenship & Residence by Investment

Visa and Permanent Leave to Remain

• Initial visa issued for 3 years and 4 months

• Then renewed for 2 years

• Only renewed if you have complied with all conditions, including no more than

180 days’ absence per year

• After 5 years you can apply for permanent leave to remain

Citizenship & Residence by Investment

Entrepreneur’s Visa

• Requirements:

• English language capability

• £200,000 to invest – or

• £50,000 from one of –

• Venture capital company FSA registered

• UK Entrepreneurial Seed Funding organisation

• UK Government department

• Jobs

Citizenship & Residence by Investment

Entrepreneur’s Visa – Must be Genuine

• Must demonstrate intentions are genuine

• A business plan

• Experience and education of the investor

• Show that the investment funds are available

• Market research

Citizenship & Residence by Investment

• How will Anil be taxed in the UK? Remittance basis?

• Residence?

• Domicile?

Citizenship & Residence by Investment

Non-Resident• 16 for a leaver/46 days for an arrive

• Work abroad, present < 91 days, work in UK < 31 days

Resident• 183 days

• UK Home & no overseas home

• Work full-time

Statutory Residence Test

Connecting Factors

• Resident family

• Substantive employment

• Accessible accommodation

• 91 days presence in either of previous 2 years

• In UK more than anywhere else (leaver only)

Statutory Residence Test

• A person takes as his domicile of origin from the domicile of his father at the

time of his birth if his parents are married

• If not he takes the domicile of his mother

• Person can only acquire a new independent domicile on attaining age 16 as

indicated on the next slide

Domicile

• A person can only change a domicile by:

(a) moving to another jurisdiction

(b) with the intention of remaining there permanently or indefinitely

• Onus of proof

• Deemed domicile for income tax, capital gains tax & inheritance tax –

resident in the UK in 15 out of the last 20 years

Changing Domicile

• Taxed only on UK source income and gains and on foreign income and

gains only in so far as they are remitted to the UK

• Remittance basis charge:

• No charge in the first seven tax years of residence

• £30,000 when tax resident 7 out of 9 years

• £60,000 when tax resident 12 out of 14 years

• Loss of personal allowance

Remittance Basis of Taxation

Pre-arrival Planning

• If possible, realise gains to get new base cost

• Segregate original capital

• Beware of mixed funds

• Keep as much outside as possible

• Consider a trust

Citizenship & Residence by Investment

Anil’s Case

• Pay full tax on UK source income, includes income from £2m

investment

• All other income free from UK tax if not remitted- this applies for up

to 15 years if the remittance basis is used

• No charge for remittance basis for 7 years

• Non UK assets free from UK inheritance tax for 15 years

Citizenship & Residence by Investment

The same visa rules apply to the Isle of Man and Guernsey

• Both islands have:

• No capital gains tax

• No inheritance tax

• No wealth tax

• Low income tax

• IOM 20% capped at £150,000

• Guernsey- pay 20% on GSY income plus cap on tax on non-GSY

income of £110,000 OR cap tax on worldwide income of £220,000

UK: Too Taxing?

Brexit

• 23 June 2016 to 29 March 2019 (11am!)

• Immigration? Could be opportunities

• VAT

• Alternatives for individuals:

• Portugal (Eur500,000)

• Cyprus (Eur2m)

• Malta (Eur1.2m)

• Quick incorporation

• 17% corporate tax

• Tax neutral investment company:

• Brexit/DTAs

• R&D Tax credits

• n.b. Tax policy and prevention of evasion

• BUT:

• Banking

• VAT

Corporate position and tax

THANK YOU

www.dixcart.

com