STOP PRESS: The remittance basis is abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in FA 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.
This note is an outline of many complex issues. It summaries the position and indicates which guidance notes will provide further information.
The starting point is that UK tax liability depends on two key factors:
residence
domicile
Residence refers to the individual鈥檚 tax status on a year by year basis. Domicile is the place which a person regards as his true home.
Up until 5 April 2013, a taxpayer鈥檚 ordinary residence status was the third key factor. Ordinary residence arises as a result of a settled purpose and so looks at the position over the longer term. The concept was abolished for
Settlor-interested trustsWhat is a settlor-interested trust?A settlor-interested trust is one where the person who created the trust, the settlor, has kept for himself some or all of the benefits attaching to the property which he has given away. A straightforward example is where a settlor
Relief for employee share schemesRemuneration expenses are generally deductible for corporation tax purposes as they are considered to be incurred wholly and exclusively for the purposes of the trade. However, expenses relating to shares are usually classed as capital and are therefore not
Gilts鈥楪ilts鈥� are securities that are also known by a number of different names (eg gilt-edged securities, Government securities or treasury stock).The Government sells gilts to fund the deficit between public spending and tax receipts. Normally, the Government pays interest to the holder of the gilt