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Tax Investigations Update

 
Richard Clarke Director in PricewaterhouseCoopers' LLP Tax Investigations practice looks at current developments that affect HMRC's enquiries into claims to non-residence and non-domicile
 
The increased focus of HMRC on the tax affairs of non-domiciled clients was highlighted in this column in May. It had been apparent for some time that HMRC officers wished to review the worldwide financial affairs of these individuals which in turn raised questions as to the scope of these enquiries and the client's ability or requirement to keep the information requested.
 
There had also been a marked increase in HMRC's enquiries into claims to non-domicile status itself. And a similar upsurge in enquiries into non-residence claims with HMRC probably encouraged by cases such as Gaines-Cooper SpC 568 (the appeal is currently before the High...

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