Northern Ireland / All

This will require non-resident companies to pay UK corporation tax on their UK rental income and possibly also on their residential property gains.

Businesses should consider the issues they may have to manage when the UK leaves the EU.

We’re one of Europe’s most attractive business locations with an exceptional reputation for delivering strong returns on inward investment.

With only four months to go until April 2017 when the new UK taxation regime for non-UK domiciled individuals (‘non-doms’) takes effect, the draft legislation released in the UK Finance Bill 2017 on 5 December offers some welcome clarification of the new rules.

Non-UK domiciled individuals who are long-term UK residents will become deemed UK domiciled for all UK taxes, aligning the income tax and capital gains tax treatment with the current deemed domicile rules for inheritance tax.

The UK Government has settled on a new regime that will give a “protected” status to offshore trusts made before and not added to after, an individual becomes deemed domiciled, with settlors being charged to UK income tax and capital gains tax on benefits and capital payments received.

From 6 April 2017 UK residential property owned through certain non-UK structures will be brought within the charge to UK inheritance tax (IHT) regardless of the residence and domicile status of the ultimate owner.

All non-UK domiciled UK resident individuals (except ‘returning non-doms’) have a one–off opportunity to re-organise offshore mixed funds into their constituent parts.

In this article, Niall Campbell and Fionn Uibh Eachach consider the impact of Brexit on VAT and customs and the knock on consequences for Irish business trading with the UK.