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Emigrating abroad

08 November 2006 / John T Newth
Issue: 4083 / Categories: Comment & Analysis , Capital Gains , Income Tax , Residence & domicile , Trusts
JOHN T NEWTH FCA, FTII, FIIT, ATT outlines some of the tax consequences when a UK resident emigrates abroad.

MASS EMIGRATION ABROAD appears to be a 21st century phenomenon: thousands of UK residents now appear to be taking that path. The creation of the European Union warmer weather political events in the UK and the use of modern travel have all contributed to the decision of those who now live abroad.
There are many issues to be faced by an emigrant from the UK but one of them is taxation. In addition to UK taxation the tax system in the country of choice must be confronted as well as existing double taxation agreements between the relevant countries.

Statute and case law

Taxes Act 1988 ss 334 335 and 336 deal broadly with the residence of individuals. ITEPA 2003 Part 2 Chapter 6 comprises ss 42 and 43 which state that the Board of Inland Revenue is to determine disputes as...

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