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Welcome to Edwin Coe’s Bite Sized blog for February 2017.

It’s been a busy month outside of tax – the wrong winner of Best Picture announced at the Oscars, Claudio Ranieri sacked at Leicester City FC and the House of Commons voting to trigger Article 50. In the meantime clients (both new and existing) are starting to understand the significant level of the changes April 2017 may have on them and their structures. It’s been an incredibly busy month for the Tax team and time is running out for clients who haven’t sought to address the April 2017 changes.

Re-basing overseas assets quick facts

  • UK resident, non-domicile clients can uplift personal foreign assets (not trust or company) as at 5 April 2017
  • Includes assets held on 5 April 2017 that were situated outside of the UK between 16 March 2016 (or if later, date of purchase) and 5 April 2017
  • Individual qualifies if they have claimed the remittance basis and paid the Remittance Basis Charge before tax year 2017/18, not born in the UK and do not have domicile of origin in the UK
  • Individual not able to access remittance basis from 6 April 2017 onwards
  • Offshore funds subject to Income Tax treatment on disposal will benefit from re-basing.

Major taxation changes ahead for non-UK domiciliaries – April 2017 slides

Please follow this link to a selection of slides from a recent presentation by Sean Bannister in relation to the April 2017 changes.

Spring Budget 2017

Chancellor Philip Hammond will deliver the Spring Budget 2017 on 8 March 2017.

New joiner – Dmitri Surendran

Many of you will have the seen the press coverage regarding our new joiner, Dmitri Surendran taking up the role of Tax Director within the team. For those who didn’t, Dmitri’s most recent role was Head of HMRC Fraud Investigation Service (Special Compliance Office in old money) in London where his team of carefully selected inspectors undertook the most complex and serious civil investigations HMRC undertake (COP 8 and COP 9). In addition Dmitri was responsible for leading a number of HMRC projects in relation to the use of offshore data by the Department.

He joins the Edwin Coe Tax team to assist with clients who engage us to represent them during HMRC investigations but also to use his HMRC experience to review the structures of clients with multi-jurisdictional interests. In the age of global transparency, being able to spot risks and manage these before the approach is made will provide a real advantage for these clients. If you have clients who might be interested in talking to Dmitri, please email him on dmitri.surendran@edwincoe.com in the first instance.

Spotlight on Intellectual Property Department

Following on from last month’s Focus on Property, this month we look at Intellectual Property. The team is led by Simon Miles and they cover such matters as brand protection, copyright protection or disputes, domain name protection, registration of trade marks, assistance with patent applications and the litigation of breaches of intellectual property/copyright matters.

Best wishes for March to all and as ever, please do contact me if Edwin Coe can assist in any way.

Kind regards

Frank Strachan
Partner | Head of Tax
For Edwin Coe LLP
d: +44 (0)20 7691 4136 | e: frank.strachan@edwincoe.com

For further information or assistance please contact our Tax team.

Edwin Coe LLP is a Limited Liability Partnership, registered in England & Wales (No.OC326366). The Firm is authorised and regulated by the Solicitors Regulation Authority. A list of members of the LLP is available for inspection at our registered office address: 2 Stone Buildings, Lincoln’s Inn, London, WC2A 3TH. “Partner” denotes a member of the LLP or an employee or consultant with the equivalent standing. This guide concerns the law in England and Wales and is intended for general guidance purposes only. It is essential to take specific legal advice before taking any action.

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