Taxation of Non-Residents and Foreign Domiciliaries 15th Online Edition

Taxation of Non-Residents and Foreign Domiciliaries 15th Online Edition

(TFD Online) 15th Edition 2016/17


ISBN: 978-1-901614-68-8

Publication date: 01/09/2016

Price: £105.00 + VAT

TFD 15th Edition 2016/17


ISBN  978-1-901614-68-8 

Hard copy Price £315.00


Online edition of Taxation of Non-Residents and Foreign Domiciliaries.


The online edition is based on the text of the 15th edition of the book but with subsequent updating.


Price £105.00 plus VAT


The online edition is only available to purchasers of the hard copy of 15th Edition of TFD).


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Please contact for futher information or mulitple user enquiries.


About the author

James Kessler QC practises at the Tax Bar. He was appointed QC in 2003. He is also a member of the Bar of Northern Ireland.

James advises in particular on foreign domiciliaries, offshore entities trusts, wills and charities

Other areas of practice include prosecution of tax crime in complex cases, particularly along the avoidance/evasion faultline, and freedom of information.

James is one of the founders of the Society of Trust and Estate Practitioners, for whom he drafted the STEP Standard Provisions, and a fellow of the Chartered Institute of Taxation. James has received the Geoffrey Shindler Award for Outstanding Contribution xto the Profession.





1. Foreign Domicile: Tax Policy and Reforms
2. Wake Up and Smell the Coffee: Public debate on tax avoidance
3. Domicile
4. Deemed Domicile for IHT
5. Deemed Domicile from 2017
6. Residence of Individuals
7. Residence of Trustees
8. Treaty-Residence
9. Exit Taxes
10. Split Years: Arrival and Departure
11. Temporary Non-residence: Post-2013 Departures
11ATemporary Non-residence: Pre-2013 Departures
12. The Remittance Basis
13. The Meaning of Remittance
14. Remittance Reliefs
15. Mixed Funds
16. Income Categories and Sources
17. Trading Income
18. Entertainers and Sportspeople
19. Property Income
20. Deduction of Interest from Property Income
21. Interest Income
22. Exempt Interest of Non-Residents
23. Dividend Income
24. Royalty Income
25. Misc Sweep-Up Income
26. Employment Income
27. Travel Expenses: Employment Income Deduction
28. PAYE
29. Employment Income: DT Relief
30. Pension and Annuity Income
31. Discretionary Trusts: Income Tax
32. IIP Trusts: Income Tax
33. Settlor-Interested Trusts
34. Transfer of Assets Abroad: Introduction
35. Transfer of Assets Abroad: Transferors
36. Transfer of Assets Abroad: Non-transferors
37. Transfer of Assets Abroad: Relief From Overlapping Charges
38. Transfer of Assets Abroad: Motive Defence
39. Life Policies and Contracts
40. Offshore Funds: Definition
41. Offshore Income Gains
42. Income from Offshore Funds
43. Accrued Income Profits
44. Deeply Discounted Securities
45. Unit Trusts
46. Intermediated Securities
47. Partnerships
48. Non-Residents Income Tax Relief
49. Collection of Tax from UK Representatives
50. Investment Manager Exemptions
51. Loans from Non-Resident Companies
52. Rates of Tax
53. Personal Allowances and Annual Exemptions
54. National Insurance Contributions
55. Capital Gains of UK Residents
56. Gains of Non-Resident Settlor-Interested Trusts: s.86
57. Capital Payments from Non-Resident Trusts: s.87
58. Borrowing by Non-resident Trusts: Sch 4B
59. Gains of Non-Resident Companies
60. Capital Losses
61. Foreign Currency Issues
62. Unremitted Income: Exchange Control
63. Double Taxation Arrangements: Introduction
64. DTA Anti-Abuse Rules
65. Foreign Tax Credit Relief
66. EU Law and UK Taxation
67. Excluded Property: Definition
68. Excluded Property Exemptions
69. Wills and IOVs
70. Reservation of Benefit
71. IHT Consequences of Transfers Between Trusts
72. IHT Deduction for Debts
73. Double Inheritance Taxation: Introduction
74. IHT DTAs: India, Pakistan, Italy, France
76. IHT DTA: Switzerland
77. Foreign IHT Credit Relief
78. Marriage with Non-dom or Non-Resident
79. Private Residence Relief
80. Residential Property of Non-Residents: NRCGT
81. Family Home and Chattels: Benefit in Kind Charges
82. Corporate Residential Property
83. Pre-Owned Assets
84. Joint Accounts
85. Estates of Deceased Persons: CGT
86. Estates of Deceased Persons: Income Tax
87. Who is the Settlor?
88. Trust with Two or More Settlors 3517
89. Situs of Assets for IHT
90. Situs of Assets for CGT
91. Foreign Entities
92. Hybrid Entities
93. Control Connected Close and Related Expressions
94. Permanent Establishment and Branch/Agency
95. Disclosure and Compliance
96. Disclosure and Compliance: IHT
97. Swiss Tax Agreement
98. Criminal Law and Professional Conduct
Appendix 1: Terminology
Appendix 2: Construction of Deeming Provisions
Appendix 3: What do we mean by “Real”?
Appendix 4: Parliamentarians
Appendix 5: Visiting Forces
Appendix 6: How to Improve Residence and Domicile Taxation
Appendix 7: Reform of Offshore Anti-Avoidance Rules
Appendix 8: Issues for UK Arrival or Departure: Checklist
Appendix 9: Welsh Devolution