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esident goes non-resident for five or fewer taxyears and, whilst non-UK resident, realisesgains or (if a remittance user) remits theproceeds of certain offshore disposals. Capitalgains tax is payable at 18% or 28%. However,if the conditions for the so-calledentrepreneurs’ relief are satisfied, on disposalson and after 6 April 2011 the first £10m of anindividual’s lifetime gains within the relief issubject to capital gains tax at only 10%. (Until6th April 2010 the relief could only be availablefor the first £1m of relievable gain, from 6thApril 2010 until 22 June 2010 the first £2m ofgains were relievable and from 23 June 2010until 5 April 2011 £5m of gains wererelievable). In calculating the £10m reliefprevious relievable disposals must be takeninto account.Non-residents are not subject to UK capitalgains tax, except to the extent that they carryon a trade in the UK through a branch oragency and realise a gain from disposing of aUK asset used in or for the purposes of thattrade or used or held for the purposes of thebranch or agency.In order to be taxed on the remittance basis,taxpayers must normally have elected to betaxed on this basis and in some cases theymust have paid the so-called remittance basischarge for the tax year in question. Theremittance basis charge is £30,000 fortaxpayers who have been UK resident for sixout of the previous nine tax years. From 6 April2013 an increased remittance basis charge of£50,000 is due to be introduced for taxpayerswho have been UK resident for twelve out ofthe previous fourteen tax years.Cash need not be brought into the UK in orderto constitute a remittance: for example, payinga UK credit card bill from an offshore bankaccount constitutes a remittance to the UK andthis amount will be subject to UK income tax.UK-domiciled or deemed domiciled individualsare subject to UK inheritance tax (a form ofdeath duty payable on a deceased's estateand also on certain lifetime gifts) on theirworldwide estate. A person is deemeddomiciled in the UK if they have been residenthere for 17 out of the previous 20 tax years.Individuals who are neither domiciled nordeemed domiciled are subject to UKinheritance tax only on UK situated assets.PAGE 15

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