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Domicile
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DOMICILE
Trustees IHT exposure from 6 April 2025
Jihao Zhang
Consultant Jihao Zhang works through eight scenarios for offshore trusts
under the new long-term residence test, covering living and deceased settlors,
the IHT tail, transitional protections and the £5m cap.
Alimahomed: the Upper Tribunal gives ‘remittance’ a real world interpretation
Emily Osborne
The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).
FA 2025 review: Double remittances
Peter Vaines
Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...
Sir J Griffin v HMRC
Taxpayer had English domicile of choice
A Weis v HMRC
Judicial review concerning legitimate expectation over domicile status
Accuro Trust (Switzerland) SA v HMRC
Foreign property added to excluded property settlement when deemed domiciled is not relevant property
Other cases that caught our eye: 4 April 2025
Determining domicile: In A Weis v HMRC [2025] UKFTT 348 (TC) (21 March), the taxpayer, a Rabbi, had been born in the UK in 1949 in Manchester to a father who had been born in Eastern Europe but had come to the UK in 1938. The father had acquired...
Winners and losers under the non-dom reforms
Emma Chamberlain
Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.
The UK’s non-dom regime: the end of the road?
Dominic Lawrance
Sophie Dworetzsky
Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys)
share their views on the current tax regime for UK resident non-domiciled
individuals and what might happen under a Labour government.
Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence
Claire Weeks
Clare Maurice
Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why
returning to the UK after a period of non-tax residence is not for the faint
hearted.
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EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
HMRC name 196 deliberate tax defaulters
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Loans to participators: s 455
Modernising the taxation of distributions
One minute with... Tom Margesson