Client scenario – moving to the UK
Our client was an ultra-high net worth Pakistani citizen who lived most of his adult life in Saudi Arabia and so never previously thought about moving to the UK. Over the past few years, he and his family have increasingly been spending time in the UK, whilst their income continued to be generated in Saudi Arabia and overseas. Our client and his young family intended to remain in the UK for the short/medium term so commissioned tax advice ahead of moving to the UK. We were introduced to this client by a finance broker professional who understood all too well the benefits of taking tax advice before moving to the UK.
Our Services
We reviewed our client’s and his immediate family’s historic UK day counts, with a view to perform the UK’s Statutory Residence Tests (“SRT”). We also considered the UK-Saudi Arabia Double Taxation Agreement re Centre of Vital Interests where he was dual-resident for some tax years.
Once we ascertained the date from which our client became a UK tax resident, because strictly this was not tax advice ahead of moving to the UK, a comprehensive advisory paper with examples was prepared for him and his other advisers in anticipation of him moving to the UK for tax purposes.
We explained:
- The concept of the Remittance Basis of taxation;
- What constitutes as a ‘remittance’ (taxable, direct, indirect, constructive and non-taxable);
- The meaning of a Mixed Fund and how this should be avoided;
- How to maintain and ensure Clean Capital outside of the UK;
- How to segregate non-UK bank accounts and other investments;
- What Business Investment Relief is (for remittances of non-UK income/gains free of UK taxes), to set-up a qualifying business in the UK; and
- How to ensure a tax effective method to remit monies to the UK.
As part of our detailed written advice, we also covered our client’s current UK Inheritance Tax exposure and how that exposure would change, in the long term, if he made UK his permanent home and acquired assets here.
Outcome
We continue to act for the client and his family on a wide range of UK and international matters, including advising on specific projects and opportunities. Also, the client has introduced us to his friends who similarly needed advice ahead of moving to the UK.
Our Founder-led approach sets us apart, as every client always has direct access to the Pure Tax senior team to discuss their affairs directly.
Please note that this case study reflects the facts, circumstances and tax position at the time the project was undertaken. It has not been updated for any subsequent change in tax law or practice and must not be construed as advice, or otherwise relied upon for any purpose.
HOW CAN PURE TAX HELP?
At Pure Tax our Tax Investigation & Disclosure specialists are industry recognised and have dealt with hundreds of contentious situations with HMRC over the years. We are adept at managing interactions with the tax authorities to ensure that the investigation and disclosure processes run smoothly and that your interests are best protected.
We don’t offer tax compliance services and we don’t offer all private client advisory services. However, the focused tax advisory services we do provide are second to none. From our experience and mixed expertise, we deliver tax advice ahead of one moving to the UK meticulously.
The right help at the right time ensures that HMRC are effectively managed and enquiries and disclosures are concluded expeditiously.
Our team are experts at providing bespoke tax advisory services and resolving contentious tax issues accurately and efficiently. We are highly adept at managing our clients’ interactions with HMRC to ensure processes run smoothly and that our clients’ interests are best protected at all times.
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