内容説明
This text explains how the territorial limits of the UK fiscal legislation may be used to shelter income and capital from UK tax. It analyzes the relevant statute and case law and describes the planning opportunities which they afford. It is aimed at accountants, solicitors and financial advisers.
目次
- Part 1 Residencies: the residence of individuals
- the residence of trusts
- the residence of companies. Part 2 UK domiciliaries : offshore trusts
- offshore companies and other entities
- Section 739
- benefits Section
- the motive
- attribution of gains to the settlor
- settlements made before 19 March 1997
- tainting
- capital payments
- attribution of corporate gains. Part 3 Sheltering business profits: offshore subsidiaries
- parallel companies
- transfer pricing
- controlled foreign companies. Part 4 Non-domiciliaries domicile: planning without trusts
- settlor-interested trusts
- other trusts
- the remittance basis
- Capital Gains tax
- Inheritance tax
- acquiring UK residences. Part 5 Migration: individuals
- migration of trusts
- company migration.
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