Understanding exemptions to the source basis of tax

to tax systems

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The international adviser is faced with a mass of different tax systems, regular columnist Jonathan Crowther runs through the principles to keep in mind when dealing with clients

Tax systems begin by taxing transactions and assets located in their own jurisdiction. This is known as the source basis. However, under this basis certain transactions and assets can be excluded from the scope of tax if they are connected to persons who are not themselves connected with the jurisdiction. For instance, the UK does not tax the following UK sited transactions and assets: • Income paid to non-UK residents gross (such as bank or eurobond interest and social security pensions) or subject to a tax credit (such as dividends) or withholding tax (such as loan interest) is not s...

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