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This website provides comprehensive information about:

  1. Taxation of foreign domiciliaries
  2. Taxation of non-residents on UK income and assets
  3. Taxation of UK residents on foreign income and assets

To enter this website you need to register (create an account). To register for the year you need a copy of the associated book Taxation of Non-Residents and Foreign Domiciliaries by James Kessler QC.

If you have not (yet) bought the book you may register for a free one day trial. There is no charge for a one day trial account, but if you find the site useful, the authors invite you to make a donation to the charity Water Aid.

If you have bought a copy of the book, you can register for the edition.

To obtain the book, go to the publishers online ordering and search for Kessler.

You may enter this site once you have registered and logged in by clicking on the index below, or you can search the text.

Users can also contribute to the text and if you see anything that needs correcting or expanding, please do. A copy of the next edition of the book will be given to the user who makes the most edits. Users contributions are reviewed by Amanda Hardy.

Contents of TFD online

The initial data was the current edition of Taxation of Non-residents and Foreign Domiciliaries published September 2013. There has been a certain amount of updating, and the discussion on the deduction of debts for IHT has been rewritten in the light of further work on the FA 2013 after going to print.

Introduction
1 Foreign Domicile Tax Reform
2 Wake Up and Smell the Coffee: The Tax Avoidance Debate
3 Domicile
4 Residence of Individuals
5 Residence of Trustees
6 Treaty-Residence
7 Year of Arrival and Departure
8 Exit Taxes
9 Temporary Non-residence: Post-2013 Departures
9A Temporary Non-residence: Pre-2013 Departures
10 Remittance Basis
11 Meaning of Remittance
12 Remittance Reliefs
13 Mixed Funds
14 Employment Income
15 PAYE
16 Trading Income
17 Property Income
18 Deduction of interest in computing property income
19 Savings and Investment Income
20 Interest Income
21 Exempt Interest of Non-Residents
22 Dividends and Distributions
23 Royalty Income
24 Pension Income
25 Discretionary Trusts: Income Tax
26 IP Trusts: Income Tax
27 Settlor-interested Trusts
28 Transfer of Assets Abroad: Introduction
29 Transfer of Assets Abroad: Transferors
30 Transfer of Assets Abroad: Non-transferors
31 Transfer of Assets Abroad: Double Taxation Issues
32 Transfer of Assets Abroad: Motive Defence
33 Life Policies and Contracts
34 Offshore Funds - Definition
35 Offshore Funds Gains
36 Income from Offshore Gains
37 Accrued Income Profits
38 Deeply Discounted Securities
39 Unit Trusts
40 Intermediated Securities
41 Partnerships
42 Non-Residents Income Tax Relief
43 Collection of Tax from UK Representatives
44 Investment Manager Exemptions
45 Loans from Non-Resident Companies
46 Rates of Tax
47 Personal Allowances
48 National Insurance Contributions
49 Capital Gains of UK Residents
50 Gains of Non-Resident Settlor-Interested Trusts: s.86
51 Capital Payments from Non-Resident Trusts: s.87
52 Borrowing by Non-resident Trust: Sch 4B
53 Gains of Non-Resident Companies
54 Capital Losses
55 Foreign Currency Issues
56 Exchange Control
57 Double Taxation Agreements: Introduction
58 Foreign Tax Credit Relief
59 DTAs: Interaction with UK tax legislation
60 EU Law and UK Taxation
61 Deemed Domicile for IHT
62 Excluded Property for IHT
63 Reservation of Benefit
64 IHT Consequences of Transfers Between Trusts
65 IHT Deduction for Debts
66 IHT Planning Before and After a Change of Domicile
67 IHT on Death: Wills and IOVs
68 Double Inheritance Taxation: Introduction
69 IHT DTTs India, Pakistan, Italy, France
70 IHT DTT USA
71 IHT DTT Switzerland
72 Foreign IHT Credit Relief
73 UK Domiciliary Married to Foreign Domiciliary
74 The Family Home and its Chattels
75 High Value Residential Property
76 Pre-Owned Assets
77 Joint Accounts
78 Estates of Deceased Persons: CGT
79 Estates of Deceased Persons: IT
80 Who is the Settlor?
81 Trusts with Two or More Settlors
82 Situs of Assets for IHT
83 Situs of Assets for CGT
84 Foreign Entities
85 Control Connected Close and Related Expressions
86 Permanent Establishment & Branch/Agency
87 Disclosure and Compliance
88 Swiss Tax Agreement Introduction
89 STA Clearance Facility
90 STA Withholding Tax
91 Disclosure of Information by Swiss Authorities
92 Criminal Law and Professional Conduct
Appendix 1: Terminology
Appendix 2: Construction of Deeming Provisions
Appendix 3: Members of Parliament
Appendix 4: Visiting Forces
Appendix 5: Students
Appendix 6: How to Improve Residence and Domicile Taxation
Appendix 7: Reform of Non-Residence Anti- Avoidance Rules
Tables



If you want further advice

If you do not find the answer to your question in TFD online, or if you want advice on which you can legally rely, you may instruct James Kessler QC to advise. For further information see How to instruct James Kessler QC.

TFD archive editions

There are archive editions for TFD 2008/09, 2009/10, 2010/11, 2011/12, and 2012/13. These will occasionally be useful to investigate the tax position in those years, but the current edition will generally be the best starting point, as that has been substantially rewritten in the light of current HMRC guidance and further thought and research.

Contact

If you have technical problems, or problems logging in, click here

To contact James Kessler QC click here

To contact Amanda Hardy, who reviews online contributions, click here

To contact the publishers of Taxation of Non-Residents and Foreign Domiciliaries click here

For multiple user licences, or to install on a firm's intranet, contact the publishers.

Technical notes

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