The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).
As everyone knows both the Conservative government and the Labour party have proposed replacing the current rules for non-domiciliaries (i.e. the remittance basis and territorial rules for inheritance tax) with new residence-based regimes.
This will mean that the SRT assumes even greater importance in our tax code.
There is no doubt that the SRT is both a significant improvement on the old common law residence rules that applied before 6 April 2013 and the outdated and subjective concept of domicile.
However the rules are often not as clear cut as they first appear. Below is an overview of ten recent difficulties that we have encountered in practice...
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The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).
As everyone knows both the Conservative government and the Labour party have proposed replacing the current rules for non-domiciliaries (i.e. the remittance basis and territorial rules for inheritance tax) with new residence-based regimes.
This will mean that the SRT assumes even greater importance in our tax code.
There is no doubt that the SRT is both a significant improvement on the old common law residence rules that applied before 6 April 2013 and the outdated and subjective concept of domicile.
However the rules are often not as clear cut as they first appear. Below is an overview of ten recent difficulties that we have encountered in practice...
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:
