International Individuals

Having decided to create an offshore trust, the settlor must next consider: where should the trust be located and what legal system should govern it? This practice note sets out the key issues that the settlor and his advisers should bear in mind when deciding on the jurisdiction for an offshore trust. To view James Corbett QC's profile, click here.

This practice note provides an introduction to the purpose and interpretation of double tax treaties.

This practice note contains links to the double taxation treaties and tax information exchange agreements (TIEAs) signed by the UK (where available in electronic form), as well as links to the double taxation treaties and TIEAs signed by a selection of other jurisdictions.

A note discussing the issues to consider where an overseas company is involved in the disposal of land situated in England and Wales.

A list of current interest rates that are useful for private client practitioners, with links to earlier rates. It includes interest on pecuniary legacies and the statutory legacy, interest on tax paid late and overpaid, Court Funds Office rates, the Bank of England base rate and the official rate of interest (used to calculate the taxable benefit from beneficial loans and pre-owned assets).

This note explains the role of notaries and what notarisation means. It outlines the types of documents that are notarised and explains what legalisation and apostille mean. It includes a checklist of what to consider when instructing a notary.

A note on the points-based business immigration system, its implications for employers and how the sponsorship licence works.

This legislation tracker is an archive of items removed from PLC Private Client legislation tracker, including Acts where provisions of interest to private client practitioners have been in force for at least a year, Bills that are not proceeding and Law Commission projects where the government has introduced a Bill in Parliament or published a draft Bill for consultation, or where it appears that the government will take no further action.

A note tracking the progress of the Finance Act 2010, Finance (No.2) Act 2010 and Finance (No.3) Act 2010 as a whole, and the progress of specific measures that are of interest to private client practitioners from the 2009 Pre-Budget Report, March 2010 Budget, June 2010 Budget and other announcements to enactment.

A note tracking the progress of the Finance Bill 2012 as a whole and specific tax measures of interest to private client practitioners.  It covers developments from August 2011 to July 2012 inclusive, with links to information on earlier and later developments.

A practice note about the Finance Act 2012 measure creating a new tax relief for foreign income or capital gains brought to the UK by a remittance basis taxpayer for the purpose of making a commercial business investment in an unlisted company or a company listed on an exchange-regulated market (such as AIM or PLUS-quoted). We would welcome subscribers' comments on the practical operation of the relief (see Your comments). NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see 2013 Budget: key private client tax announcements.

This is a practice note about the remittance basis charge for long-term UK residents under section 809H of the Income Tax Act 2007. NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see 2013 Budget: key private client tax announcements.

This practice note covers the meaning of "residence" and "ordinary residence" of individuals in the context of UK taxation. NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see 2013 Budget: key private client tax announcements.

This practice note sets out in detail the UK tax implications of residence, ordinary residence and domicile for individuals. NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see 2013 Budget: key private client tax announcements.

A practice note about the statutory residence test (SRT) for individuals that the government intends to introduce in the Finance Act 2013. Once in force, the SRT will determine whether an individual is UK resident for tax purposes for the tax years 2013-14 onwards. We would welcome subscribers' views on the practicalities of operating the SRT, see Your comments.

A note containing tables of CGT rates, main exemptions and reliefs, deadlines for returns and payments, and time limits for assessments and claims, with links to interest rates on CGT paid late and overpaid CGT, and to more detailed information about CGT.

A note containing tables of inheritance tax (IHT) rates, main exemptions and reliefs, deadlines for returns and payments, and time limits for assessments and claims, with links to interest rates on IHT paid late and overpaid, and to more detailed information about IHT. It includes some information about capital transfer tax (CTT) and estate duty.

A document tracking the development of certain notable pieces of proposed new legislation relating to finance taxation.

A practice note on the taxation of capital payments to UK beneficiaries of offshore trusts under section 87 of the Taxation of Chargeable Gains Act 1992. NOTE: This resource is being reviewed in light of the 2013 Budget. For more information, see 2013 Budget: key private client tax announcements.

This note provides an overview of the UK/Switzerland tax co-operation agreement to tackle tax evasion by UK taxpayers holding funds in Swiss bank accounts. The agreement came into force on 1 January 2013. The note discusses the anonymous one-off payment to settle past tax liabilities, the withholding tax on income and capital gains going forward and the one-off withholding tax on death. It also looks at the requirements for disclosure as an alternative to these deductions, further protection in the agreement for HMRC (such as information requests) and options for UK residents with Swiss bank accounts. We would welcome subscribers' views on the practical implications of the agreement (see Your views). Note: this resource is being reviewed in the light of the 2013 Budget. For more information, see Legal update, 2013 Budget: key private client tax announcements.

This Practice note gives an overview of how the work permit scheme worked and contains a brief section on the Highly Skilled Migrants Programme (HSMP). These are the "old rules", although for the time being, Romanian and Bulgarian nationals may still apply for work permits. For details of the current rules on business immigration, see Practice note, Points-based immigration and the sponsorship licence.