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Domicile disputes: actions speak louder than words

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HMRC continue to challenge taxpayers’ domicile status successfully. The recent cases of Strachan, Coller and Shah demonstrate the increasing scepticism with which the First-tier Tribunal approaches uncorroborated declarations of intention, and the factors it will take into account when determining the value of witness evidence, including the fallibility of memory and the witness’ relationship to the taxpayer. Procedural points also continue to play a pivotal role in domicile disputes. Taxpayers who intend to rely on a non-UK common-law domicile should collate substantial objective evidence of their domicile status, or will face unanticipated tax liabilities if HMRC’s challenge is successful.

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