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How pre-UK residence offshore income and gains of a non-domiciled individual can remain outside of the UK tax net.
KEY POINTS
- UK resident but non-UK domiciled individuals can live off their “clean capital” throughout their stay in the UK and not incur tax.
- Clean capital must be appropriately segregated or “ringfenced” so that it cannot be mixed with foreign income and gains arising after the client becomes tax resident in the UK and be subject to the mixed fund rules.
- Those who are actively trading or investing can use trusts if they are set up correctly.
- Clean capital can be used as security for a bank loan which can be invested offshore in income and capital gains producing assets.
- Offshore investment bonds can preserve access to clean capital and offer other potential benefits.
Ensuring tax-efficient access to “clean capital” is one of the most important tax matters for a non-UK...
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