What is the impact of HMRC’s revised guidance? Ed Dwan and Lucy Sauvage examine the current position
In the middle of July HMRC released via its website some draft guidance regarding company residence which subject to comment and subsequent amendments will form part of their International Manual for use by Inspectors and practitioners alike. At first glance and in headline form it could appear that these guidelines will be helpful when considering company residence cases where there is some UK activity but we wish to maintain that the company is tax resident overseas.
However on closer inspection it seems that they are not so beneficial. Given the potential for misinterpretation this article seeks to explain precisely what this guidance means with a few examples to demonstrate when it will apply. Finally in
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What is the impact of HMRC’s revised guidance? Ed Dwan and Lucy Sauvage examine the current position
In the middle of July HMRC released via its website some draft guidance regarding company residence which subject to comment and subsequent amendments will form part of their International Manual for use by Inspectors and practitioners alike. At first glance and in headline form it could appear that these guidelines will be helpful when considering company residence cases where there is some UK activity but we wish to maintain that the company is tax resident overseas.
However on closer inspection it seems that they are not so beneficial. Given the potential for misinterpretation this article seeks to explain precisely what this guidance means with a few examples to demonstrate when it will apply. Finally in
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
