Leaving aside the question of residence here , my client spent quite a large part of the year in the US last year - he purchased a car in 2011 12 and it has subsequently been sold in 2012 13 - assuming that he is paying UK tax what sort of CAs will be available if any - any other pointers welcome. Nick
PS a want to get a per diem deduction for clients days in US what will HMRC wear , cant find anything when i search
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If you have a relevant business activity...
... taxable in the UK, then you're entitled to capital allowances to the extent that you incur capital expenditure (on plant and machinery) for the purposes of that business activity.
Since it's not EC registered...
... it won't have a qualifying emissions certificate and can't therefore be a low emissions car, as defined, meaning it will have to go in the special rate pool (or, if there's private use, a single asset pool with WDAs at the lower rate).
For US tax purposes one depreciates the entire cost of the car but subject to limitations depending on the cost, and recovered in the year of sale.
Your client will also need to file US tax returns for 2011 and 2012 and you will need to know the US tax payable for these years to calculate the US tax claimable in the UK as a credit on any doubly taxed income.
David Treitel
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