内容説明
The new edition of this rtitle explains how the territorial limits of the UK tax code may be used to shelter income and capital from UK tax. It analyses the relevant statute and case-law and describes the planning opportunities which they afford. This edition includes practical analysis of planning opportunities, thorough analysis of anti avoidance legislation, extended treatment of non domiciliaries and a new part looking at existing offshore structures.
目次
- Part I Territorial Limits: of UK Tax
- Residence of individuals
- Residence of Trusts
- Residence of Companies. Part II UK Domiciliaries: Offshore Trusts
- Offshore companies
- Existing settlor - interest settlements
- Existing children's settlements
- Investment products. Part III Non Domicilaries: Domicile
- Planning without trusts
- Excluded property settlements
- The remittance basis
- Capital gains tax
- Inheritance tax. Part IV: The integrity of offshore structures
- Sham trusts
- Distributions and existing settlements
- Shadow directors
- Non-domiciliaries and UK homes Part V Anti-Avoidance Legislation: Section 739
- Benefits: section 740
- The motive defence: section 741
- Attribution of gains to the settlor
- Tainting
- Capital payments
- section 87
- Trustee borrowing
- Attribution of corporate gains
- Offshore funds
- Life policies. Part VI Sheltering Business Profits
- Offshore subsidiaries
- Parallel companies
- Transfer pricing
- Controlled foreign companies. Part VII Migration: Individuals
- Migration of trusts
- Company migration.
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