Oliver Marre (5 Stone Buildings) examines the FTT’s landmark decision that provides the first judicial treatment of some fundamental questions on the remittance basis code.
It is curious given the complexity of the relevant statutory provisions and HMRC’s interest in non-UK domiciled taxpayers that there has been so little litigation on the remittance basis code found in ITA 2007. Perhaps it is a sign of the degree of care which taxpayers and advisers give to getting it right; but if that is so it does not explain why by contrast there is so much litigation in other areas of taxation.
It is therefore both useful and somewhat surprising that the First-tier Tribunal (FTT) has now heard the case of Sehgal v HMRC [2022] UKFTT 312 (TC). Useful because it provides the first judicial treatment of some fundamental questions. Surprising because at...
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Oliver Marre (5 Stone Buildings) examines the FTT’s landmark decision that provides the first judicial treatment of some fundamental questions on the remittance basis code.
It is curious given the complexity of the relevant statutory provisions and HMRC’s interest in non-UK domiciled taxpayers that there has been so little litigation on the remittance basis code found in ITA 2007. Perhaps it is a sign of the degree of care which taxpayers and advisers give to getting it right; but if that is so it does not explain why by contrast there is so much litigation in other areas of taxation.
It is therefore both useful and somewhat surprising that the First-tier Tribunal (FTT) has now heard the case of Sehgal v HMRC [2022] UKFTT 312 (TC). Useful because it provides the first judicial treatment of some fundamental questions. Surprising because at...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
