Our client had a domicile of choice in South Africa. Over the years he accumulated non-remittable income and capital gains within an offshore structure. If this income and capital gains had been remitted to the UK it would have been subject to income and capital gains tax.
The client came to Satis Tax to see how he could rearrange his offshore affairs to a position where he could be able to remit that income and gains to the UK without incurring tax liabilities.
With our guidance, the solution was that he managed to ensure that he became a non-UK resident for a period of time, and then prior to his return a successful reconstruction of his offshore investments and assets was undertaken. This effectively converted all realised gains and income into capital, which he could then remit to the UK tax-free.