The proposed statutory residence test should give greater certainty and less scope for interpreting the rules by taxpayers, advisers and HMRC. Thresholds have increased, but not as much as many would like, and some, no doubt, would prefer a pure day count test but that has been rejected. Record keeping remains crucial. The addition of transitional rules is an improvement and the abolition of ordinarily residence in general a simplification. More than 75 years ago the Income Tax Codification Committee concluded that the lack of clarity around ‘residence’ was intolerable. We may finally be close to resolving that but ‘clarity’ does not necessarily mean ‘simplicity’ and difficult cases will remain.
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