STATUTORY-RESIDENCE-TEST

The Upper Tribunal’s decision in McCabe shows how difficult it can be to challenge findings of fact when confronted with multi-factorial tests, writes Oliver Marre (5 Stone Buildings).

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).

Liam McKay

Robert Waterson

The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).

Dominic Lawrance

Catrin Harrison

Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.

Peter Vaines

HMRC comes to the rescue.

Natalie Quail

Andrew Goldstone

Andrew Goldstone and Natalie Quail (Mishcon de Reya) review the latest tax developments affecting private clients, including the three key consultations.

Andre Anthony

Andre Anthony (CMS Cameron McKenna) explains the tax issues arising on the importation of a private jet into the EU by a non-EU resident.

Priya Dutta

Priya Dutta answers a query on the tax residency of employees seconded to overseas offices and undertaking training in the UK

Jane Scott

Carolyn Steppler

Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed