Tolley's Expatriate Tax Planning 2010-11

Product Details

Tolley’s Expatriate Tax Planning covers the taxation of both UK individuals working overseas and foreign nationals working in the UK. Combining technical depth with practical planning points and risk avoidance strategies throughout, using this title will help ensure assignment costs are kept to a minimum. The third edition incorporates a full revision of content to reflect the new Finance Act 2009 rules affecting expatriates, the introduction of a statutory residence test and Capital Taxes.

• Plan international assignments in advance
• Find solutions and answers to issues that arise in regard to existing employment situations
• Deal with expatriate employee issues without recourse to third-party specialist advice

• An Extensive New Chapter on Capital Taxes
• Domicile & residence – Update for HMRC's completely re-written guidance on residence and ordinary residence (replacing Booklet IR20). New guidance on the practical operation of the new day-counting rules for 2008/09 onwards. Commentary on decision in important tax case of Revenue and Customs Commissioners v Grace
• Taxation of earnings – New HMRC guidance on the tax and NICs liability on conditional bonuses. Remittance basis for earnings in practice, including extension of Statement of Practice SP 5/84 for 2008/09 and the replacement Statement of Practice for 2009/10. Guidance regarding remittances from mixed accounts and the payment of the Remittance Basis Charge by employers. Planning to use the terms of a double tax treaty to avoid the remittance basis charge and to claim the tax allowances denied by the UK remittance basis legislation
• Pensions – Coverage of new HMRC guidance on participation in non-UK pension schemes, including contributing to both a UK and a non-UK plan, and the transfer of UK pension funds to a non-UK pension plan. Implications of EC action against UK's discriminatory pensions legislation
• Share-based incentives – The new HMRC guidance on the remittance basis rules for 2008/09 onwards, including double tax and NICs issues
• Double taxation – Guidance on double tax relief for the Remittance Basis Charge under the UK domestic rules and double tax treaties. HMRC's application of new OECD guidance on day counting and the economic employer issue in double tax treaties
• Social security contributions – Application of EC rules to payment of UK state benefits to non-residents
• Directors – New legislation and HMRC guidance on shadow directors' non-UK accommodation
• Seafarers – New HMRC Manual coverage of the seafarers' 100% deduction. Commentary on the important case of Torr and Others v CIR
• PAYE and NICs compliance – The new modified PAYE and NICS arrangements for 2008/09 onwards for expatriate employees
• HMRC organisation – Details of the ongoing re-organisation of the work of HMRC's Expatriate Teams

• New Remittance basis claim exceptions (flowchart)
• New Capital double tax treaties list
• Updated HMRC contact details
• Updated double tax treaty list and 183-day rule information