Non-UK Domiciled

At Dixon Wilson we are experienced in advising non-UK domiciled individuals on their UK tax affairs.

Whether you are planning to move to the UK, seeking advice on how to structure your affairs as an existing resident of the UK, or thinking of leaving the UK, we are able to help you make sense of the increasingly complicated and ever-changing 'non-dom' rules.

Residence

For those individuals who are looking to move to the UK or leave the UK, or indeed those who habitually spend any significant time here, it is crucial that they understand what their tax residency position is, and how this impacts on the taxation of their affairs.

We have considerable experience advising international clients on their residency status, as well as developing strategies to ensure individuals legitimately secure the best tax advantages for their personal circumstances.

Domicile

Whilst residence is largely defined by physical presence in the UK, an individual’s domicile is not defined by UK tax legislation but is instead a common law concept, which is not synonymous with residence or nationality.

The rules governing domicile can seem complex but we are able to provide clear advice on whether you are likely to be domiciled in the UK or not, and the steps you can take to strengthen any argument supporting your domicile.

Remittance basis of taxation

Individuals who are not domiciled in the UK can elect to be taxed on the remittance basis. This potentially offers the opportunity to shelter your income and gains, to the extent that they do not bring the funds to the UK, from UK taxation.

The remittance basis is a complicated area of taxation and professional advice must be sought before considering whether it is appropriate for you. At Dixon Wilson we can guide you through the various rules to assist you.

Our services include:

Analysing bank accounts held outside the UK from which funds will be remitted;

Identifying clean capital which can be remitted to the UK free of tax;
Calculating the UK tax liability arising from the remittance of foreign income or gains;
Alerting you of the pitfalls of deemed or constructive remittances;
Advice on the segregation of bank accounts to mitigate UK tax on future remittances;
Liaising with your non-UK bankers and other professional advisers to ensure you receive a consistent and efficient service.

Longer term residents in the UK currently need to pay the remittance basis charge in order to claim the remittance basis of taxation each year. We can provide advice on how to structure your affairs in order that you only pay the remittance basis charge in years when it is beneficial to do so.

Arrivers and leavers

The most crucial stage of planning for a non UK domiciled individual is either before they have arrived in the UK, if they are coming to live here, or before they leave the UK, if they are moving abroad. We have experience of the vast array of issues which need to be considered, ranging from analysing double tax treaties to providing advice on how you can secure an investor visa.

Significant amounts of tax can be saved by taking straightforward advice prior to your arrival or departure in relation to the structuring of your affairs. We are able to provide advice quickly and efficiently to assist you if you are working to a short timescale.

Long term residents

Individuals who have lived in the UK for a significant period of time but are not UK domiciled face different challenges, particularly where they have not maintained a source of clean capital outside of the UK.

We can help you with areas such as:

Tax planning in relation to mixed funds which have been partially derived from foreign income and gains;
Gifting assets, both in the UK and outside the UK, to family members, other individuals and charities;
Borrowing funds outside the UK to remit without crystallising an immediate tax liability;
Remitting funds to invest in UK businesses tax efficiently;
The inheritance tax implications of living in the UK in the longer term, including the implications of becoming 'deemed domiciled'.

Compliance and dealing with HM Revenue & Customs

HM Revenue & Customs require any individual who is resident in the UK and wishes to claim the remittance basis of taxation to submit an annual tax return.

We can help you with areas such as:

Registering your arrival in or departure from the UK with HM Revenue & Customs;
Preparing your annual UK tax return;
Calculating and advising you of your tax liabilities well in advance of payment deadlines;
Liaising with HM Revenue & Customs on your behalf, including dealing with any enquiries or investigations;
Liaising with tax authorities in other jurisdictions in relation to your UK tax position;
Advising on the records which need to be kept.

Property and ownership structures

Non-UK domiciled individuals who wish to own property in the UK are presented with a number of ownership options. We are able to advise on the implications of the various structures and how they are taxed in the UK, to help decide the most suitable solution for you.

We can also suggest the most appropriate method of funding the acquisition if funds are to be remitted from outside of the UK. Alternatively, we can review existing structures if the property has already been acquired, to ensure maximum tax efficiency.