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Non-UK resident with UK based share dealing account
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Non-UK resident with UK based share dealing account
Hello all,
I have a question.
I currently have a UK based share dealing account. However, I recently became a non-UK resident. I now work in the Middle East. I have informed the company which administers my account and they have informed me that they will now share my account details with HMRC. In the account, I have holding in UK domiciled companies as well as non-UK domiciled holdings.
My question is what should I expect to happen next?
I have a question.
I currently have a UK based share dealing account. However, I recently became a non-UK resident. I now work in the Middle East. I have informed the company which administers my account and they have informed me that they will now share my account details with HMRC. In the account, I have holding in UK domiciled companies as well as non-UK domiciled holdings.
My question is what should I expect to happen next?
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Re: Non-UK resident with UK based share dealing account
It depends. Do you still have a UK contact address they can use? If yes, you may well be OK. If not, thy may want to freeze or possibly close the account. Each broker has a different approach. I have a UK contact address, but do not volunteer any other information unless necessary.
As for telling HMRC - Provided you are/will be paying any tax due, this should not be an issue. I declare and pay tax on my dividends via Self Assessment. As I am a buy and hold investor there is no cgt.
As for telling HMRC - Provided you are/will be paying any tax due, this should not be an issue. I declare and pay tax on my dividends via Self Assessment. As I am a buy and hold investor there is no cgt.
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Re: Non-UK resident with UK based share dealing account
BBLSP1 wrote:It depends. Do you still have a UK contact address they can use? If yes, you may well be OK. If not, thy may want to freeze or possibly close the account. Each broker has a different approach. I have a UK contact address, but do not volunteer any other information unless necessary.
Yes, I've always taken the view that businesses are entitled to an address where post can be sent to me, but they are not entitled to know where I live. It's quite simply none of their business(*). So in a case like this, that requirement can be satisfied by a UK postal address no matter where you reside.
And anyone can get themselves a public mailbox for a few quid a month, that will receive and hold post for you. For an extra amount they will periodically forward your post to wherever you are.
(*) There are a couple of specific exceptions. Your insurer and mortgage bank may have a reasonable basis for knowing whether you actually live in a property that is insured or mortgaged with them.
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Re: Non-UK resident with UK based share dealing account
Well I am a bit more above board than that. My UK address is my UK accommodation address, although it is not my home, using the definitions of ‘accommodation’ and ‘home’ as given in HMRC Guidance Note RDR3.
Although I am non-resident, and my home is currently outside the UK, it is the address HMRC has for me and it counts as my accommodation tie in assessing residency. However, I have no other UK ties, so can still easily spend normal vacation periods in the UK whilst remaining non-resident. As to my other whereabouts, all that the Self Assessment return requires is to state the country of residence, nothing else needed.
Although I am non-resident, and my home is currently outside the UK, it is the address HMRC has for me and it counts as my accommodation tie in assessing residency. However, I have no other UK ties, so can still easily spend normal vacation periods in the UK whilst remaining non-resident. As to my other whereabouts, all that the Self Assessment return requires is to state the country of residence, nothing else needed.
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Re: Non-UK resident with UK based share dealing account
BBLSP1 wrote:Well I am a bit more above board than that. My UK address is my UK accommodation address, although it is not my home, using the definitions of ‘accommodation’ and ‘home’ as given in HMRC Guidance Note RDR3.
Although I am non-resident, and my home is currently outside the UK, it is the address HMRC has for me and it counts as my accommodation tie in assessing residency. However, I have no other UK ties, so can still easily spend normal vacation periods in the UK whilst remaining non-resident. As to my other whereabouts, all that the Self Assessment return requires is to state the country of residence, nothing else needed.
If you think I was suggesting anything that was not "above board", then you misunderstood me. I was merely opining that a broker does not need to know where you live, only where you can be reached by post. You appear to agree with that by virtue of your use of a UK accommodation address, which is equivalent to a public or private mailbox address.
I did not say anything about what address you should use in your communications with HMRC. Obviously if you are claiming to be non-resident for tax purposes then you will need to make those representations to HMRC. That has nothing to do with other parties you do business with.
So by all means tell the taxman you are in Qatar or wherever. But there is no need to tell your broker.
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Re: Non-UK resident with UK based share dealing account
Lootman wrote:So by all means tell the taxman you are in Qatar or wherever. But there is no need to tell your broker.
Don't both FATCA and CRS now compel UK brokers to ask about, and potentially confirm, a customer's 'tax residency'?
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Re: Non-UK resident with UK based share dealing account
Probably. I was trying to draw a distinction between what you need to disclose for tax purposes and what you need to disclose for operational purposes. I think your point takes us full circle - when BBSLP1 said this . .
BBLSP1 wrote:It depends. Do you still have a UK contact address they can use? If yes, you may well be OK. If not, thy may want to freeze or possibly close the account. Each broker has a different approach. I have a UK contact address, but do not volunteer any other information unless necessary.
. . I think he was referring to the fact that some brokers don't want clients who are not resident in the UK. The reason for that is that a non-resident client creates extra regulatory work and risk for the broker.
So BBSLP1's advice to use a UK address was to bypass the risk of having your account closed for that reason. BBSLP1's advice also was to "not volunteer any other information unless necessary". If your broker makes it "necessary", by explicitly asking about your country of residence, then you have a dilemma about how to answer that. If you are honest about living in Qatar then you may lose that account.
Do brokers assume residency from the address you give them?
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Re: Non-UK resident with UK based share dealing account
Lootman wrote:Do brokers assume residency from the address you give them?
My sense is that they now ask for 'tax residency' as a separate and distinct thing, with the ability to select more than one (for unfortunates such as US citizens living in the UK, who have to live under at least two, and perhaps three, overlapping and often conflicting tax regimes).
FATCA has several 'indicia', one of which is 'US place of birth' and so clearly not necessarily connected to a residence address. And at least one UK broker now refuses accounts point-blank to anyone who ticks 'Yes' to the 'US place of birth?' question. CRS is less concerned with citizenship, but since it is otherwise pretty much aligned with FATCA, brokers and banks tend to address both with the same set of know-your-customer questions, backed up by passport and other document copies if considered necessary.
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Re: Non-UK resident with UK based share dealing account
Lootman wrote: Do brokers assume residency from the address you give them?
I side with your 'direction of thought' in this Lootman.
From my experience it is best to get your various account structures (current, trading etc) set up before you expat, as when you're already away you'll find a much smaller subset who can still deal with you if you then choose to try and open accounts. And IME, if you later get challenged 'But you live abroad, you have to close your account' - you can answer along the lines of you don't 'live' there, you just spend a lot of time working there or similar.
I go through this with Interactive Brokers every few years as we move country. They keep trying to switch the entity where my account is held, which can automatically bring with-holding tax/local reporting etc. I keep arguing and demonstrating that for tax purposes our household is perhaps akin to being permanently on a cruise ship, located in one place in one time, but never taxably resident anywhere... ball in their court.
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Re: Non-UK resident with UK based share dealing account
I presume that these enquiries from the financial institutions are to give them the necessary cover from regulatory sanctions should you later prove to be a drug lord, gun runner, people trafficker or communist etc. They can state that they asked you about such things and you advised them that you were not.
Provided instead, and much more likely on the hallowed boards of LF, that you are a regular law abiding citizen, struggling through the world without asking for hand-outs, doing your bit for charity along the way and paying your taxes, it should not really matter to the financial institutions themselves what your status is, to them it is, or should be, just welcome business.
Or am I being too pragmatic, in a world of seemingly endless ‘small print’, whereby, if your circumstances are that of an outlier, the computer will invariably say ‘No!’?
Provided instead, and much more likely on the hallowed boards of LF, that you are a regular law abiding citizen, struggling through the world without asking for hand-outs, doing your bit for charity along the way and paying your taxes, it should not really matter to the financial institutions themselves what your status is, to them it is, or should be, just welcome business.
Or am I being too pragmatic, in a world of seemingly endless ‘small print’, whereby, if your circumstances are that of an outlier, the computer will invariably say ‘No!’?
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Re: Non-UK resident with UK based share dealing account
No there is nothing 'dodgy' going on, your analogy with 'computer says no' is reason enough for the non-standard customer to face problems. Try opening a UK bank account from abroad and you'll get a taste of it, almost no bank will touch you. This is why I strongly recommend any Brit planning to 'expat' for a while, to get all/any financial accounts set up and running before they depart. I found this out when I had to open a new UK bank a/c from abroad, the paperwork all had to be certified by embassies/lawyers etc [$], and the choice of UK a/c offerings I had was small and also $.
Underlying it re: a share-trading account/brokers could be other things. Some international brokers have a requirement that a client is serviced from their local regional office, with the a/c held within their local corporate legal entity*. That local office will have presumptions re: the client's liability to the likes of withholding tax on dividends. If you're non-standard then 'computer says no' and you can expect an uphill struggle.
*Example: If you're a Brit and move from England to say a country in Asia. An international broker might require you to move your holdings into an account under their regional Asian office. They'll then assume you are subject to your new locations tax laws, even if you aren't [which they might not understand/believe, since they're usually not 'global tax experts']. It can get very messy, and with a bit of pre-planning an expat heading off on say a typical 2-3 year stint can probably avoid it happening at all.
Underlying it re: a share-trading account/brokers could be other things. Some international brokers have a requirement that a client is serviced from their local regional office, with the a/c held within their local corporate legal entity*. That local office will have presumptions re: the client's liability to the likes of withholding tax on dividends. If you're non-standard then 'computer says no' and you can expect an uphill struggle.
*Example: If you're a Brit and move from England to say a country in Asia. An international broker might require you to move your holdings into an account under their regional Asian office. They'll then assume you are subject to your new locations tax laws, even if you aren't [which they might not understand/believe, since they're usually not 'global tax experts']. It can get very messy, and with a bit of pre-planning an expat heading off on say a typical 2-3 year stint can probably avoid it happening at all.
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Re: Non-UK resident with UK based share dealing account
DiamondEcho wrote: I keep arguing and demonstrating that for tax purposes our household is perhaps akin to being permanently on a cruise ship, located in one place in one time, but never taxably resident anywhere... ball in their court.
Digressing a little, but the idea of being resident nowhere for tax purposes is something that intrigues me. Not only would you pay no tax but you wouldn't even need to report or declare anything.
As a practical matter, it may not be possible or affordable to achieve that state. You'd either need to be moving from one nation to another every few weeks, or else you'd need to live on some kind of ship, as you note. (I recall from somewhere there is such a ship out there, where you can buy a cabin on it and just sail the seas, resident nowhere. It wasn't cheap).
However I believe that the UK will only accept you as non-resident if you establish residency is some other country first. So it would be a two-step process. First lose UK residency by living in another country for over one year. Then move from that country to your "stateless" location.
More trouble than it's worth, probably, given that there are many tax havens that you could choose to live in. But it's an interesting thought experiment.
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Re: Non-UK resident with UK based share dealing account
Lootman wrote:DiamondEcho wrote: I keep arguing and demonstrating that for tax purposes our household is perhaps akin to being permanently on a cruise ship, located in one place in one time, but never taxably resident anywhere... ball in their court.
Digressing a little, but the idea of being resident nowhere for tax purposes is something that intrigues me. Not only would you pay no tax but you wouldn't even need to report or declare anything.
As a practical matter, it may not be possible or affordable to achieve that state. You'd either need to be moving from one nation to another every few weeks, or else you'd need to live on some kind of ship, as you note. (I recall from somewhere there is such a ship out there, where you can buy a cabin on it and just sail the seas, resident nowhere. It wasn't cheap).
However I believe that the UK will only accept you as non-resident if you establish residency is some other country first. So it would be a two-step process. First lose UK residency by living in another country for over one year. Then move from that country to your "stateless" location.
More trouble than it's worth, probably, given that there are many tax havens that you could choose to live in. But it's an interesting thought experiment.
I managed to do that many years ago. Was living in France on assignment, with part of the deal a large portfolio run by the company. Moving back to uk, went to the tax man (women in this case) to get a certificate to allow me to employ a removal company to leave. This was final tax position in France. Then got my company to sell all the shares and put money in my French bank. Two days later we got back to the uk after a trip through europe. By then shares sold. Arrived back in uk told tax man I am back. End of tax year filled in form. No tax on the shares....
Was in between.
Raptor
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Re: Non-UK resident with UK based share dealing account
Dear All,
Thank you for your comments.
I was obligated to tell my broker about my change of residency as it is in my terms and conditions.
Yes, I have a UK address that I can use as per HMRC Guidance Note RDR3.
Thank you all for your help.
Thank you for your comments.
I was obligated to tell my broker about my change of residency as it is in my terms and conditions.
Yes, I have a UK address that I can use as per HMRC Guidance Note RDR3.
Thank you all for your help.
Re: Non-UK resident with UK based share dealing account
I would be very grateful for some help and advice. I have been a TDW customer for approaching 20 years. Since the take over I've had more problems than all the previous time holding the account. Today though has taken the biscuit. I tried to log in only to be told I needed to supply extra information. Two items in particular - a mobile phone number and a UK National Insurance number I do not have. Where I live and work there is no usable mobile signal. I get by quite happily without. I cannot supply a UK NI number as I'm not a UK resident. I can see this might be a problem trying to set up any other account. Is there a sensible broker out there suitable for a non-resident HYP style investor of UK shares ? Is there another approach I can use. I am no longer growing my HYP, just drawing dividends, so trades are very few in number. I just need to be able to hold the shares and a few gilts I have and draw the dividend income, occassionaly reinvesting surplus cash. ![Sad :(](./images/smilies/icon_e_sad.gif)
![Sad :(](./images/smilies/icon_e_sad.gif)
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Re: Non-UK resident with UK based share dealing account
Lootman wrote:DiamondEcho wrote: I keep arguing and demonstrating that for tax purposes our household is perhaps akin to being permanently on a cruise ship, located in one place in one time, but never taxably resident anywhere... ball in their court.
Digressing a little, but the idea of being resident nowhere for tax purposes is something that intrigues me. Not only would you pay no tax but you wouldn't even need to report or declare anything.
As a practical matter, it may not be possible or affordable to achieve that state. You'd either need to be moving from one nation to another every few weeks, or else you'd need to live on some kind of ship, as you note. (I recall from somewhere there is such a ship out there, where you can buy a cabin on it and just sail the seas, resident nowhere. It wasn't cheap).
However I believe that the UK will only accept you as non-resident if you establish residency is some other country first. So it would be a two-step process. First lose UK residency by living in another country for over one year. Then move from that country to your "stateless" location.
More trouble than it's worth, probably, given that there are many tax havens that you could choose to live in. But it's an interesting thought experiment.
@Lootman, I recall being in this position for two tax years. It has minuses as well as pluses. regards, dspp
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Re: Non-UK resident with UK based share dealing account
MoVert wrote:I would be very grateful for some help and advice. I have been a TDW customer for approaching 20 years. Since the take over I've had more problems than all the previous time holding the account. Today though has taken the biscuit. I tried to log in only to be told I needed to supply extra information. Two items in particular - a mobile phone number and a UK National Insurance number I do not have. Where I live and work there is no usable mobile signal. I get by quite happily without. I cannot supply a UK NI number as I'm not a UK resident. I can see this might be a problem trying to set up any other account. Is there a sensible broker out there suitable for a non-resident HYP style investor of UK shares ? Is there another approach I can use. I am no longer growing my HYP, just drawing dividends, so trades are very few in number. I just need to be able to hold the shares and a few gilts I have and draw the dividend income, occassionaly reinvesting surplus cash.
@MoVert - When I was in expat mode I used Charles Stanley as my broker. It is certainly a more individualised experience but you pay extra for the privilege. May be worth enquiring if they can assist so as to have a fall back position. regards, dspp
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Re: Non-UK resident with UK based share dealing account
MoVert wrote:I cannot supply a UK NI number as I'm not a UK resident.
I'm not sure I follow this. If you have an NI number then it's yours for life, no matter where you reside, and you could certainly enter it here. TD and every other UK broker/platform will soon insist on an NI number associated with accounts, if they don't already do so. All part of getting information flows to HMRC to enable 'making tax digital'.
Or are you saying you do not have a UK NI number at all? That would be a harder crack to paper over...
On the mobile phone part, I live in an area with great mobile phone coverage but I don't possess a mobile phone! A quick message to Interactive Investor was enough to make that 'requirement' go away for me. Perhaps that might work for you too.
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Re: Non-UK resident with UK based share dealing account
MoVert wrote: Two items in particular - a mobile phone number and a UK National Insurance number I do not have.
The NI Number requirement comes from an EU Directive whose UK implementation requires all transactions to be reported to the FSA. There is an alternative that can be used which is a combination of part of your surname and date of birth. It's the identifier which was used from the 1970s on driving licences. If ii don't accept this, then they are gold plating.
As regards a phone number, I would have thought this wasn't compulsory and a land line number would be acceptable or failing that a number formatted like a phone number that wasn't actually one. It may be part of their security procedure for reset of passwords that a text message is sent. UK landlines can usually intercept text messages and read them out to you.
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Re: Non-UK resident with UK based share dealing account
MoVert wrote:Two items in particular - a mobile phone number and a UK National Insurance number I do not have. Where I live and work there is no usable mobile signal. I get by quite happily without. I cannot supply a UK NI number as I'm not a UK resident. I can see this might be a problem trying to set up any other account. Is there a sensible broker out there suitable for a non-resident HYP style investor of UK shares ? Is there another approach I can use. I am no longer growing my HYP, just drawing dividends, so trades are very few in number. I just need to be able to hold the shares and a few gilts I have and draw the dividend income, occassionaly reinvesting surplus cash.
The UK-NI number, if you've ever had one then it's yours for life, well that's my understanding. It's necessary to have a UK-NI number to file UK tax returns, even when non-resident. That applies to many UK expats, anyone renting out their former home for example.
re: mobile number, that sounds to me like simple 'computer says no' box-ticking mentioned up-thread. They are presuming everyone has a mobile; they're probably using it to triangulate some form of confirmation of your ID/credit record based on an assumption all applicants are UK based...?
There are other brokers who will take non-resident Brits. But since they might be liable for foreign tax reporting to the government of the country where you live, IME this rules out smaller and domestically focused UK brokers.
I've moved my Interactive Brokers account with me across three non-UK countries. I opened it when living in Germany, but the dox required to open the account, at least the passport copy, had to be certified by the local British embassy. There are other box-ticking hurdles, like copies of utility bills (none of which were in my name), bank statements (maintaining a UK bank account is wise in this respect), but I explained my situation to them and the account was opened - that was now about 10 years ago, and generally speaking I'm very happy with them.
- I'd be interested to hear if anyone else has experience of holding a brokerage a/c trading mainly UK shares who has managed to open and/or maintain it whilst abroad. AFAIUI the possible brokerages that can do this are pretty limited, at least if you take out the full-service/$$$ ones.
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