From Peter Vaines, Squire Sanders, writing in UK Tax Bulletin, September 2013
It will take a long time before the various uncertainties in the new statutory residence test are resolved and it is only residence nerds who will keep agonising over all the various points. However every now and again something really important pops up which deserves wider comment. It may be remembered that there was a problem with the automatic residence test about the amount of time you spend in your foreign home. That has now been resolved by the latest HMRC guidance but there is another serious issue.
Nobody takes much notice of the automatic tests because they tend to be applicable only in the most obvious circumstances. Not so. Under the automatic UK residence test you will be...
