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IR 20: 'Guidance' or Concession?

Robin Mathew QC of New Square Chambers considers whether the emigrant taxpayer has any remedy if HMRC unreasonably refuses to apply the IR 20 rules
In the exercise of its managerial powers 1HMRC publishes an important booklet in pretty pinkishpurple covers designated IR 20 and called Residents and Non Residents: Liability to tax in the United Kingdom. Soon it may become a battleground between HMRC and the emigrant taxpayer. The Gaines-Cooper case2 may be the first shot in that battle.
The law v HMRC practice
There is now a startling divergence on a fundamental point between the law and HMRC practice as officially applied.3 The Special Commissioners in Gaines-Cooper...

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