Sehgal v HMRC is a landmark decision on the construction and application of Conditions A and B of the remittance basis code in ITA 2007 s 809L. Looking at arrangements for the discharge of a debt, the FTT has found that, in Condition A, the word ‘property’ should be narrowly construed and the word ‘services’ should be given a wide meaning; and, in Condition B, it is fundamentally important to identify what is, in fact, remitted. The taxpayers were victorious, and the case will be of interest to all private client advisors with non-UK domiciled clients.
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Sehgal v HMRC is a landmark decision on the construction and application of Conditions A and B of the remittance basis code in ITA 2007 s 809L. Looking at arrangements for the discharge of a debt, the FTT has found that, in Condition A, the word ‘property’ should be narrowly construed and the word ‘services’ should be given a wide meaning; and, in Condition B, it is fundamentally important to identify what is, in fact, remitted. The taxpayers were victorious, and the case will be of interest to all private client advisors with non-UK domiciled clients.
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:
