A particular niche of Charter Tax is being able to look after clients’ international planning requirements. Although we are not part of a formalised network, we have contacts in most jurisdictions with whom we work and have built up a trusted relationship over the years, to provide our clients with the services they need.
Our ability to look after both personal and corporate international tax planning needs places us in an ideal position to look after individuals, such as internationally mobile entrepreneurs and high net worth individuals moving jurisdiction, as well as corporates wishing to grow or restructure internationally.
Janet Paterson is well known for a number of authoring projects on international tax matters, such as her chapter for Tolley’s on the Remittance Basis. As such, Janet stays at the forefront of such cross-border tax planning and regularly advises both her own private clients as well as other more generalist accountancy practices.
Our specialism for international private client tax work in particular focuses on clients coming to or going from the UK.
Non-domiciliaries living in the UK are a key area of work for Charter Tax and ideally we will work with such clients from the moment they contemplate coming to the UK until the moment they leave – and beyond. Ideally we will always work with a client to structure their affairs properly before coming to the UK, though even where clients have not had the benefit of good pre-entry planning, there will normally be things that we can do to improve their position. Particular areas we can help with include:
- Helping our clients plan their affairs before coming to the UK, to maximise their then ability to live in the UK tax-free.
- Working with suitable immigration lawyers, if necessary, to attend to all relevant immigration issues.
- Working with suitable offshore trustees to establish or review any offshore trust arrangements.
- Helping our clients then ensure that on an ongoing basis they maximise the availability of the remittance basis, by appropriately planning how they structure their income and gains going forward.
- Looking at any employments or directorships our clients have, to ensure that these are appropriately handled to both minimise any UK income tax obligations for the individual, and also ensure that the individual’s work in the UK does not have any unforeseen negative impact for the company in terms of UK corporation tax issues.
- Ensuring our clients take full advantage of reliefs such as the business investment relief available such that funds brought into the UK for certain investments.
- Helping our clients plan how to structure any property purchase, either as an investment or as a home in which to live.
- Helping our clients plan in advance of becoming “deemed domiciled” in the UK.
As well as looking after our non-dom clients, we also have a large focus on ex-pats living abroad. Such clients will often have quite different requirements, depending on whether or not they plan to return to the UK and, if so, within what time frame. Issues that often arise for such clients, and on which we are very well placed to advise, will include:
Reviewing the UK residency rules to ensure that the ex-pat has genuinely ceased to be UK resident – and planning when he may re-commence residence.
Looking at whether the ex-pat is abroad for only a short stay (in particular less than 5 years) and, if so, whether he will need to be aware of any issues under the rules for “temporary non-residents” and, if so, how best to plan against this.
Looking at whether it may be possible for the ex-pat to be out of the UK for long enough to cease to be domiciled in the UK, and how best an ex-pat may increase his chances of achieving this.