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RESIDENCE
Corporate re-domiciliation Panel Report: potential impact on structuring inward bound re-domiciliation
Freddie Schwier
Dominic Foulkes
Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.
Home and away: how to go non-resident after McCabe
Oliver Marre
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).
Much ado about non-doms: the new policy paper
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) examine what
we know now following this week’s policy paper.
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
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).
The non-doms reforms: a practitioner view
Helen McGhee
Helen McGhee (Joseph Hage Aaronson) considers how practitioners should be advising clients during this uncertain time.
The new Luxembourg/UK double tax treaty
Irfan Butt
Andrew Seidler
Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.
The statutory residence test: an exceptionally useful case on ‘exceptional circumstances’
Catrin Harrison
Dominic Lawrance
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.
UK corporate re-domiciliation: time to make a move?
Jill Gatehouse
Josh Critchlow
Alison Dickie
Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.
Temporary non-residence: the anti-avoidance rules
Nigel Giles
Michael Flaherty
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.
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15
EDITOR'S PICK
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
1 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
2 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
3 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
4 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
5 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
6 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
7 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
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
NEWS
Read all
HMRC manual changes: 28 February 2025
Government proposes further Finance Bill amendments, including to the temporary repatriation facility
Business rates relief for film studios
HMRC advisory fuel rates
Scottish landfill tax rates
CASES
Read all
The executors of L Elborne deceased and others v HMRC
Chelsea Cloisters Management Ltd v HMRC
HMRC v Asset House Piccadilly Ltd
Other cases that caught our eye: 28 February 2025
A Taxpayer v HMRC
IN BRIEF
Read all
Statutory residence: but why do you need to be here?
Ramsay reined in?
HMRC’s focus on PE firms’ VAT compliance
HMRC’s U-turn on limited partners
Salaried members update
MOST READ
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
Finance Bill 2025 progress
Sonder Europe and serviced apartments: TOMS or no TOMS?
B Joseph v HMRC