From 6 April 2013 OWR will only be available to individuals who claim to be taxed on the remittance basis if they are not domiciled in the UK have not been resident at any time during the three tax years prior to the year of arrival and it is reasonable to assume that the employee will not be based in the UK beyond the end of the second full tax year after the year of arrival. The draft legislation specifically defines the meaning of ‘based’ in the UK.
At first glance the proposed test appears broadly similar to the current test for being ‘resident but not ordinarily resident’ (R/NOR) and thereby entitled to OWR under current legislation. However closer examination reveals that this...
