Domicile status procedure:E Embericos v HMRC[2022] UKFTT 464 (TC) (7 December 2022) may seem familiar to readers as this is another skirmish in the long drawn-out procedural argument about the taxpayer’s domicile position. You may recall that previously the taxpayer wished to have his domicile status determined as a discrete issue. He therefore sought to require HMRC to issue a partial closure notice dealing only with his domicile status. This would have meant that if he was found not to be UK domiciled he would not be required to provide details of his unremitted income. He was unsuccessful in that attempt. HMRC subsequently issued an assessment bringing an estimated amount of unremitted income into charge on the basis that the taxpayer was UK domiciled. He appealed against that assessment.
This decision was about whether or not the domicile issue should be considered in a preliminary hearing or...
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Domicile status procedure:E Embericos v HMRC[2022] UKFTT 464 (TC) (7 December 2022) may seem familiar to readers as this is another skirmish in the long drawn-out procedural argument about the taxpayer’s domicile position. You may recall that previously the taxpayer wished to have his domicile status determined as a discrete issue. He therefore sought to require HMRC to issue a partial closure notice dealing only with his domicile status. This would have meant that if he was found not to be UK domiciled he would not be required to provide details of his unremitted income. He was unsuccessful in that attempt. HMRC subsequently issued an assessment bringing an estimated amount of unremitted income into charge on the basis that the taxpayer was UK domiciled. He appealed against that assessment.
This decision was about whether or not the domicile issue should be considered in a preliminary hearing or...
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:
