In Henkes, the tribunal decided it can decide a taxpayer’s domicile status when determining an application for the closure of a domicile enquiry, as Nick Clayton and Dawen Gao (Herbert Smith Freehills) explain.
In the context of domicile investigations HMRC has with increased regularity and vigour taken the position that the individual under investigation has acquired a domicile of choice within the UK. In consequence HMRC have issued information notices requiring the production of extensive information about the individual’s non-UK affairs (on the basis that as a UK domiciliary the individual is not entitled to pay tax on the remittance basis).
This trend is regarded by many as relatively bold on the part of HMRC. This is because it requires HMRC to adduce cogent evidence (which is most readily available to the taxpayer) of that which can be...
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In Henkes, the tribunal decided it can decide a taxpayer’s domicile status when determining an application for the closure of a domicile enquiry, as Nick Clayton and Dawen Gao (Herbert Smith Freehills) explain.
In the context of domicile investigations HMRC has with increased regularity and vigour taken the position that the individual under investigation has acquired a domicile of choice within the UK. In consequence HMRC have issued information notices requiring the production of extensive information about the individual’s non-UK affairs (on the basis that as a UK domiciliary the individual is not entitled to pay tax on the remittance basis).
This trend is regarded by many as relatively bold on the part of HMRC. This is because it requires HMRC to adduce cogent evidence (which is most readily available to the taxpayer) of that which can be...
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:
