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RESIDENCE
The statutory residence test: ten things we find very difficult about you
Claire Weeks
Aoife McCauley
The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Other cases that caught our eye: 19 January 2024
The meaning of ‘residence’ for LBTT purposes: A Blue v Revenue Scotland [2023] FTSTC 4 (21 December 2023) is a case on the additional dwelling supplement rules for Scottish land and buildings transaction tax, particularly the rules relating to...
Why constructive ambiguity is sometimes the best policy
Jeremy Mindell
Jeremy Mindell (Primondell) believes that judicial interpretation of existing
legislation is preferable to a wholesale codification of the law that would
become outdated and easy to manipulate.
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Jersey’s economic substance rules
Rupert Lee
Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.
Private client review for April 2020
Andrew Goldstone
Moustapha Hammoud
Andrew Goldstone and Moustapha Hammoud (Mishcon de Reya) provide a
monthly update.
UK residence: exceptional days
Peter Vaines
HMRC comes to the rescue.
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
HMRC issue coding notices Direction
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
Read all
Exclusive purposes
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
MOST READ
Read all
Tyler Security Ltd v HMRC
Time to bring back Budget purdah?
‘Partnership NICs’: the impact on the asset management sector
Consultation tracker
Eurocent (Buckingham) Ltd v HMRC