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Statutory residence test: the end of the ‘clean break’

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The end of the ‘distinct break’ on the introduction of the statutory residence test means that high net worth individuals looking to become non-UK resident can now spend more time in the UK and keep more connections than was previously advisable. The reduction of uncertainty gives more flexibility in advising. There is no need for a long period without UK visits at the start of a period of non-UK residence. Individuals can now count UK ties and arrive at a number of days which can be spent in the UK. The UK family home can be retained, sometimes even without an accommodation tie. UK directorships can be retained, provided UK work days are limited. Many other connections, such as major UK shareholdings and club memberships, no longer need to be considered.

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