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RESIDENCE
The statutory residence test: ten things we find very difficult about you
Claire Weeks
Aoife McCauley
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).
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Other cases that caught our eye: 19 January 2024
The meaning of ‘residence’ for LBTT purposes: A Blue v Revenue Scotland [2023] FTSTC 4 (21 December 2023) is a case on the additional dwelling supplement rules for Scottish land and buildings transaction tax, particularly the rules relating to...
Why constructive ambiguity is sometimes the best policy
Jeremy Mindell
Jeremy Mindell (Primondell) believes that judicial interpretation of existing
legislation is preferable to a wholesale codification of the law that would
become outdated and easy to manipulate.
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Jersey’s economic substance rules
Rupert Lee
Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.
Private client review for April 2020
Andrew Goldstone
Moustapha Hammoud
Andrew Goldstone and Moustapha Hammoud (Mishcon de Reya) provide a
monthly update.
UK residence: exceptional days
Peter Vaines
HMRC comes to the rescue.
EDITOR'S PICK
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
1 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
2 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
3 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
4 /7
2024: that was the year that was
Jemma Dick
5 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
6 /7
The tractor tax
Stuart Maggs
7 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
NEWS
Read all
HMRC manual changes: 31 January 2025
Consultation on HMRC statistics publications
Government launches independent loan charge review
Finance Bill amended, but further changes expected
LTT relief extended to Anglesey tax sites
CASES
Read all
Bryan Robson Ltd v HMRC
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
Other cases that caught our eye: 31 January 2025
HMRC v BlueCrest Capital Management (UK) LLP
ScottishPower (SPCL) Ltd and others v HMRC
IN BRIEF
Read all
BlueCrest: the CA ruling on Condition B
Tweaking the Temporary Repatriation Facility
ScottishPower: payments under settlement agreements
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
MOST READ
Read all
Global by Nature Ltd v HMRC
Pillar Two one year on: what have we seen and where are we going?
HMRC v BlueCrest Capital Management (UK) LLP
The Trump effect: US foreign tax policy
HMRC v Sonder Europe Ltd