International Tax Conference

Edward Hayes, Burges Salmon

The new tax year launches the start of a new era for individuals moving to or from the UK.  Some of the changes represent a cutting back of the existing tax reliefs enjoyed by ‘Non-Doms’ but in other ways the new regimes will actually be broader in their application. For example, British ex pats could find themselves benefiting from the new rules if and when they return to the UK and the changes to inheritance tax will affect many people who would never have dreamt of claiming Non-Dom status. Whilst replacing domicile with residence as the key connecting factor in almost all cases will bring some welcome certainty for many, there are also plenty of nuances to work through. The sessions will include illustrations, consider action points for pre and post 5 April 2025 and highlight pitfalls and planning opportunities.

This session will cover:

• A reminder of the existing regime for Non-Doms.
• The distinctions to be drawn between new arrivals into the UK and those already here.
• What clients in either camp should be considering doing ahead of 6 April 2025.
• How the 4-year FIG regime and Overseas Workday Relief will operate from 2025/26 onwards.
• How this might impact clients’ banking/investment choices.
• The transitional rules for existing remittance users and in particular the Temporary Repatriation Facility.
• High level comments on the impact for settlors and beneficiaries of trusts (although this will be covered in more detail in the later trust session).
• Planning considerations.

Edward Hayes, Burges Salmon

This session will cover:

• A reminder of the existing rules for ‘excluded property’.
• How the new concept of ‘Long-Term Residence’ will work in practice.
• How the new IHT ‘Tail’ will operate and the different applications.
• Why domicile will remain relevant in some cases.
• High-level comments on the impact for settlors and beneficiaries of trusts.
• Planning considerations.

Edward Hayes, Burges Salmon

This session will cover:

• A reminder of the existing tax regime for non-UK resident trusts.
• The key Income Tax and Capital Gains Tax (CGT) changes for settlors and beneficiaries.
• The key IHT changes for trustees, settlors and beneficiaries.
• The distinction to be drawn between discretionary and life interest trusts.
• The difference that living or deceased settlors will make.
• How the Temporary Repatriation Facility will operate in relation to trusts.
• Planning considerations.

Pat Nown, Mercia Group

This session will cover:

• A number of factors in very recent years has created unprecedented changes as to how and where people work or carry out business or retire. Covid, Brexit, living costs and digital developments have all contributed to cross border mobility. UK direct personal taxes are to be based on residence alone. This means that it is critical to have clarity on how the UK Statutory Residence Test (SRT) operates.This short refresher session will consider the application of the rules using specific practical scenarios.
• Content to include:
  • A refresher of procedure and key tests.
  • Worked examples of UK leavers including split year basis.
  • Worked examples for UK arrivals.

Tim Kelsey, Kelsey’s Payroll Services

Global trade continues to grow, despite political uncertainty. Companies continue to send employees on assignments into and out of the UK, and there are significant payroll consequences that result. This session considers the issues in a post-Brexit world and explains the significant variations to standard HMRC processes available to ensure compliance. The session is targeted at payroll, tax and HR professionals who have some responsibility for the administration of payroll records for secondees.

This session will cover:

• The scope of PAYE liability for those coming to the UK.
• Double Taxation Agreements and how to use them.
• Business visitors and EPAPP4.
• Modified PAYE schemes EPAPP6.
• Annual PAYE schemes EPAPP8.
• Net of Foreign tax Credit Relief EPAPP5.
• A walk through a typical foreign payslip from a UK taxation perspective.

Tim Kelsey, Kelsey’s Payroll Services

This session will cover:

• The UK/EU Trade and Cooperation Agreement.
• Reciprocal social security agreements and certificates of coverage.
• UK NIC and the 52-week rule for Rest of World jurisdiction.
• Modified Nic schemes EPAPP7a and 7b.

The session will provide worked examples illustrating how to operate the special variants to the UK PAYE procedure, and will also include short interactive exercises to demonstrate the learning points.

• Identify to which employees UK PAYE and payroll reporting requirements apply.
• Operate the various variants to standard PAYE procedure when processing expatriate employee payroll records.
• Understand how the UK/EU arrangements detailed on the trade and co-operation agreement work in practice.
• Apply the correct NIC rules to assignees as determined by where they are travelling from/to.

James Hurst, Mercia Group

This session will highlight some recent developments affecting cross border trade, including:

• Recent HMRC activity - import and export compliance.
• Carbon Border Adjustment Mechanism (CBAM) - an overview.
• ‘VAT in The Digital Age’ (ViDA) - an update on VAT changes taking place in the EU.
• A selection of recent VAT cases and case studies.