tax investigation services

Individuals with cross-border issues often have complicated tax affairs. The legislation tends to be fraught with anti-avoidance provisions that can easily catch out the taxpayer or agent who doesn’t deal with it on a daily basis. The HMRC’s no-nonsense approach to non-compliance can result in high penalties meaning that taxpayers and their agents need to be sure of the correct UK tax position.

The statutory residence test was introduced in April 2013. While this now allows individuals to correctly determine their residence status, it is also inflexible and arguably one of the most complicated in the world – as such, a person can accidentally become UK resident and end up with an unexpected tax liability. Split-year treatment may be available to individuals coming to or leaving the UK during a tax year, but this is no longer available to everyone and it is important to check the conditions.

UK resident non-doms can benefit from special tax treatment but legislation needs to be monitored as legislation is again changing. Planning opportunities are still available for well-advised non-doms to structure their affairs tax efficiently either before they move to the UK or after they have started to live here.


We have specialists that have a day to day practical working knowledge of individuals with offshore or cross-border issues and can provide advice and assistance on the following:

Residence - review of status, planning and compliance services
  • individuals emigrating overseas
  • individuals coming to live or work in the UK
  • individuals living overseas but who come to the UK for work or social visits
  • employees who are sent overseas to work
  • obtaining residence certificate from HMRC
Domicile - review of domicile status, planning and compliance services
  • foreigners who come to the UK and have foreign income/gains
  • remittance basis of assessment
  • overseas earning relief for foreigners recently moved to the UK
  • bringing funds to the UK tax efficiently
  • long-term resident non-doms and the April 2017 capital gains tax rebasing
  • cleansing mixed offshore bank accounts
  • long-term residents due to become deemed domiciled in the UK
  • tax implications of taking a UK domicile of choice
  • UK doms emigrating permanently overseas
  • non-doms born in the UK with a UK domicile of origin – the tax implications of living in or returning to the UK
  • inheritance tax planning for non-doms
Offshore trusts - advice, planning and compliance services
  • non-doms settling new offshore trusts
  • the implications of the April 2017 changes for non-dom settlors of existing offshore trusts
  • UK resident beneficiaries of offshore trusts
  • non-resident trustees of offshore trusts owning UK sited assets or wrapped UK residential property, or that have UK resident beneficiaries
Double tax treaties - how the treaties apply and compliance services
  • treaty residence
  • non-residents receiving income from the UK
  • UK residents receiving income from overseas
  • treaty relief claims
Non-residents capital gains tax (NRCGT) - planning and compliance services
  • non-residents disposing of UK residential property
  • filing of NRCGT returns to HMRC
  • interaction with temporary non residence rules
Non-residents acquiring UK residential property - advice, planning and compliance services
  • whether to acquire personally or in a company or a trust/company wrapper
  • SDLT implications of purchase
  • annual tax on enveloped properties (ATED) for company ownership
  • inheritance tax
  • loans from non-dom lenders
  • application to receive rents without UK withholding tax
  • UK tax return service for non-resident landlords
  • NRCGT and ATED-CGT on the disposal of UK residential property
Worldwide offshore disclosure facility - advice and compliance
  • review of UK tax position to determine if affairs need to be regularised
  • disclosures to HMRC
  • calculating tax, interest and penalties

In addition, we can provide assistance to UK trustees who need to understand their status for the purposes of FATCA and the Common Reporting Standard (CRS).

Please contact our team of specialists who would be happy to discuss how we can help:

Karen Bowen Partner / Gordon Fox Partner



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