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The statutory residence test: ten things we find very difficult about you

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It is anticipated that a new residence-based regime will replace the current non-dom rules with effect from 6 April 2025 (depending, of course, on the outcome of the 4 July election and any consultation by the new government). Although the SRT is undoubtedly a much clearer and more objective basis for determining an individual’s liability to UK tax than domicile, and the statutory residence rules are better than the old common law, there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply.

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