Residency & Domicile / VCT EIS Flashcards
1st Overseas Test
- Resident 1 of 3 last tax years
- spend <16 days in UK
2nd Overseas Test
- Not resident any of last 3 tax yrs
- <46 days in UK
3rd Overseas Test
- Work Full time overseas (35hr avg)
- <91 days in UK
- of which <31 days working
1st UK Test
Spend >183 days in UK
2nd UK Test
- Own, Rent, Live in a house for 91 consecutive days (30 in tax year)
- If you own a foreign home - live in it for <30 days
3rd UK Test
- Work Full Time in UK for 365 days
- 75% of days must be in UK (that worked 3hrs)
- At least one working 3hrs in UK
What are the 4 types of domicile?
1) Deemed - (15 of 20yrs in UK)
2) Choice - move somewhere permanently
3) Origin - where father is born (or dead dad / out of wedlock)
4) Dependancy - any new domicile from parents when <16
VCT Income Tax:
30% on 200k
clawed back if disposed of before 5 years
cannot be carried back
can transfer to spouse or die
VCT Dividends
VCT pays no corp tax on disposals
Disposals can be disbursed as tax free dividends to investors
VCT CGT
Gain are tax exempt - no minimum holding period
Cannot be used for CGT losses
VCT Risks (4)
1) Liquidity - unlisted shares (also due to 5yr holding period)
2) More sensitive to economy / macro
3) inexperienced management teams
4) NAV +-
EIS Income Tax:
1) 30% on 1mil
2) further 1 mil in “knowledge intensive companies”
3) can be carried back to the previous year (if there is scope to do so)
EIS CGT:
Gains become CGT exempt after 3 years
(5yrs if held before apr 2000)
Can be used as CGT loss (after 3 yrs)
EIS BR / IHT
100% relief after 2 years
EIS company size?
1) <250 employees
2) <15m in gross assets
3) can raise 5m per year
