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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 bought a copy of the book, you can register for the life of the edition. To obtain the book, go to the publishers online ordering and search for Kessler.

If you have not (yet) bought the book associated with this site, you may register for a free one day trial. There is no charge for a one day trial, but if you find the site useful and wish to express support or thanks, the author invites you to make a donation to the charity Water Aid.

If you registered before the current edition was published in September 2014, you need to reregister with the password in the current edition. Registration for an earlier edition will not be valid.

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 correct slips or errors 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. User contributions are reviewed by Amanda Hardy QC. Users of TFD online will be delighted to congratulate Amanda on her appointment as Queens Counsel.

TFD 2015/16 edition out soon

The new 2015/16 edition of "Taxation of Non-residents and Foreign Domiciliaries" will be published on 1 September 2015. To maintain unbroken access to TFD online you will need a copy of the new edition and an online licence (which will no longer be available free with a copy of the book). To obtain the book, go to the publishers online ordering and search for Kessler; to order a licence click here

Online licences for the current edition will not be valid from 1 September 2015 when the new edition is published.

Contents of TFD online

The initial data was the current edition of Taxation of Non-residents and Foreign Domiciliaries published 1 September 2014. There has been a certain amount of updating. The discussion on remittances where debts are secured on foreign income/gains (as collateral), which is in the supplement to the printed book, is in chapter 11 of TFD online.

1 Foreign Domicile: Tax Policy and Reforms
2 Wake Up and Smell the Coffee: Public Debate on Tax Avoidance
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 Income Sources and Categories
15 Trading Income
16 Property Income
17 Deduction of interest in computing property income
18 Interest Income
19 Exempt Interest of Non-Residents
20 Dividend Income
21 Royalty Income
22 Employment 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: Relief from Overlapping Charges
32 Transfer of Assets Abroad: Motive Defence
33 Life Policies and Contracts
34 Offshore Funds - Definition
35 Offshore Income Gains
36 Income from Offshore Funds
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 Unremitted Income: 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
71 IHT DTT Switzerland
72 Foreign IHT Credit Relief
73 UK Domiciliary Married to Foreign Domiciliary
74 The Family Home and its Chattels
75 Corporate 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: What Do We Mean by "Real"?
Appendix 4: Members of Parliament
Appendix 5: Visiting Forces
Appendix 6: Students
Appendix 7: Entertainers and Sportspeople
Appendix 8: How to Improve Residence and Domicile Taxation
Appendix 9: Reform of Non-Residence Anti- Avoidance Rules

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, 2012/13, and 2013/14. 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 written in the light of current HMRC guidance, and further thought and research.


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

To contact James Kessler QC click here

To contact Amanda Hardy QC, 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

TFD online is in technical terms a Wiki on the lines of Wikipedia, but only registered users can edit this wiki.

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