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Europe’s Number One Tax Havens!

From whichever angle, there is no doubt that the premier tax havens in Europe – at least for non-British and Irish people – are the United Kingdom and Republic of Ireland. Whilst this may sound unbelievable, it is in fact absolutely true and all deriving from a shared historical anomaly relating to the tax treatment of non-UK or Irish domiciled individuals. In fact, the anomaly is undoubtedly the reason why both countries have an unusual concentration of ‘international’ millionaires and indeed billionaires within their boundaries. Indeed, without these tax concessions there is little doubt that either country could ‘flout’ such dynamic and disproportionately large financial sectors or expertise, which is currently the case. 

Fiscal Benefits for Non-Domiciled UK & Irish Individuals

The United Kingdom and the Republic of Ireland are unique in Europe in making a distinction between a person’s domicile and residence for tax purposes. In fact, in the case of both capital gains and inheritance tax, a well advised UK or Irish resident but non-domiciled individual can often legally, subject to double taxation treaties, avoid such taxes even where investments are in the UK or Ireland. This is normally achieved by selling the shares in an offshore company and not any property itself - Further, income tax responsibilities for non-domiciled individuals are limited to either those sums directly generated in the UK or Ireland and/or such sums remitted to the UK/Ireland from abroad. In other words, if there is an offshore holding vehicle to prevent direct remittances, such foreign income will remain free of all British/Irish tax (see British Inland Revenue Booklet 20 in respect of remittance payments to non-domiciled residents). The significance of such a tax system becomes clear when it is remembered, with the very notable exception of the United States, that virtually all other western countries tax their resident individuals, whether foreign or not, on the basis of their world-wide income. In the case of the United States, its citizens are prima facie liable to US taxes, subject to appropriate tax treaties, whether or not they are physically resident in the US, on sums over US$86,000.00. Thus, a German or French national who fully extricates himself from his native tax system, by becoming permanently resident in the British Isles, will find he is no longer taxed on his world-wide income and will also enjoy many other fiscal benefits denied to the respective indigenous populations. Of course, this state of affairs is the result of historical anomalies and could not be deemed an equitable tax system. However, the unique fiscal environment of Britain and Ireland has attracted large numbers of high net worth individuals resulting in considerable economic benefits. Notwithstanding the above, it should be noted that the Irish Finance Act in 2006 made slight changes to the financial position of those non-domiciled but resident and working in Ireland in that such individuals can no longer avoid Irish income tax on that proportion of their income sent abroad if it was generated through activities in the state.


Major Tax Systems: France - Germany - Spain - The United Kingdom

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