Overview

This book explains the tax consequences of the changes detailed in Part 2 of the Finance Act 2025, following the enactment of new rules announced on Budget Day 2024. These were essentially the replacement of a domicile-based system with a residence-based system and the abolition of the Remittance Basis which had been around in its current form since the beginning of the First World War. The text of the legislation is included in the publication. Each provision is analysed using the headings Overview, Relevant Legislation, Detail and Commencement. This is followed by a section on some thoughts as to how the provisions can be used for the benefit of clients. This work was originally written as a supplement to the earlier publication called Taxation of Entertainers and Sportspersons, but applies equally to personal tax advisers to mobile HNWIs.

Full Product Details

Author:   Adrian Shipwright
Publisher:   Spiramus Press
Imprint:   Spiramus Press
ISBN:  

9781913507886

ISBN 10:   1913507882
Pages:   631
Publication Date:   08 December 2025
Audience:   Professional and scholarly ,  Professional & Vocational
Format:   Paperback
Publisher's Status:   Active
Availability:   Temporarily unavailable  
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Table of Contents

Preface. ii 1      The New Residence Based Regime after Finance Act 2025. 1 1.1      Summary. 2 1.2      General. 3 1.3      The Relevant Legislation. 11 2      Specifics: Replacement of Special Rules Relating to ""Domicile. 13 2.1      Summary. 13 2.2      General. 18 2.3      Chapter 1 of Part 2 of the Act: New rules for foreign income and gains of individuals becoming UK resident. 21 2.4      Details of New Chapter 5 Part 8 ITTOIA. 39 2.5      Section 38 – The New Overseas Workday Relief. 81 2.6      Schedule 8 Relief on foreign employment income: consequential and transitional provision. 102 2.7      Abolition of the remittance basis. 119 2.8      Application of Income Tax Acts in relation to deemed employment. 143 2.9      Rebasing of assets for CGT for some former remittance basis users. 224 3      Trusts: connected amendments, transitional provision etc.. 231 3.1      Summary. 231 3.2      Further Review.. 3-234 3.3      The Legislation – section 43. 235 4      Inheritance Tax. 367 4.1      Summary. 368 4.2      Some Relevant Legislation. 4-374 4.3      Replacement of Domicile Test by Long-Term Residence Test - section 44 FA 2025   380 4.4      Long Term Residence and Excluded Property. 383 4.5      Position concerning settled property following move away from Domicile. 406 Appendix 2:     ANNEXE. 460 Appendix 3:     Inland Revenue Pamphlet IR 20 Extracts. 463 Appendix 4:     Some Relevant Definitions. 475 5      Relief for New Residents for Foreign Gains. 480 5.1      Summary. 480 5.2      Introduction. 482 5.3      Finance Bill Committee. 483 5.4      Details of new schedule D1. 487 Appendix 5:     Table of some relevant definitions. 505 6      Some first thoughts, and possibilities. 510 6.1      Summary. 510 6.2      Introduction. 513 6.3      Some approaches. 517 6.4      Putting in ""firebreaks"" - one other prophylactic to consider is the use of ""firebreaks"". 6-532 6.5      Restructuring arrangements including image rights and endorsement arrangements. 6-536 6.6      Using insurance for funding and or as a wrapper. 6-537 6.7      Starting the clock again. 6-539 6.8      Checking nationality etc and applicability of DDC.. 6-546 6.9      Fragmenting and splitting ownership. 6-550 6.10        Fixing the value and giving away the value above that. 6-551 6.11        Double Death Conventions (""DDC"") 6-561 6.12        Conclusion. 604 Appendix 6:     Some questions for clients?. 605 Appendix 7:     Table of Situs of Assets. 606 Appendix 8:     Jurisdiction Table. 625

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Adrian is a highly regarded advisor with broad experience across a range of sectors and businesses. He has particular expertise in large corporate transactions and restructuring, land development, trusts, and estates, especially intangibles, as well as celebrity and HINWI tax and cross-border matters. Adrian has had a varied career in tax as a partner in two City law firms, a tenant for many years at Pump Court Tax Chambers, and an academic at Oxford and Professor of Business Law at King's College, London. For 13 years he was a judge of the First Tier Tax Tribunal and of the Upper Tier Tribun

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