Michael Flaherty and Nigel Giles (BDO) provide a refresher guide to these intricate and wide-ranging rules which can easily be overlooked when advising on migration tax planning for individuals.
The purpose and development of the temporary non-residence rules
The temporary non-residence rules (TNR) have been with us in one form or another for the last 20 years although their scope has extended over the years. The purpose of this article is to provide a general overview of the rules and summary of the present position rather than a comprehensive review. There are particular nuances in the application of the TNR rules particularly where they interact with applicable double tax treaty provisions on residence and double tax treaty relief. Each case should be considered in the light of its specific fact pattern.
The reasoning behind the TNR legislation is straightforward. In the absence of such a measure ...
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Michael Flaherty and Nigel Giles (BDO) provide a refresher guide to these intricate and wide-ranging rules which can easily be overlooked when advising on migration tax planning for individuals.
The purpose and development of the temporary non-residence rules
The temporary non-residence rules (TNR) have been with us in one form or another for the last 20 years although their scope has extended over the years. The purpose of this article is to provide a general overview of the rules and summary of the present position rather than a comprehensive review. There are particular nuances in the application of the TNR rules particularly where they interact with applicable double tax treaty provisions on residence and double tax treaty relief. Each case should be considered in the light of its specific fact pattern.
The reasoning behind the TNR legislation is straightforward. In the absence of such a measure ...
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:
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