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Home
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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become outdated and easy to manipulate.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
Hannah McKenzie
Gavin Orpwood
Louise Keegan
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
Moustapha Hammoud
Andrew Goldstone
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
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Broad opposition to proposed ‘reckless statements’ tax offence
GfC7 points to disclosure facility for late TP corrections
Options explored for simplifying offshore anti-avoidance rules
CIOT calls for urgent changes on IHT on pensions
Normal minimum pension age protection consultation
CASES
Read all
HMRC v G Quillan
Perenco UK Ltd v HMRC
HMRC v C Candy
Property 118 Ltd and another v HMRC
Ten cases shaping tax practice in 2026
IN BRIEF
Read all
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
HMRC’s annual report for 2025/26
MOST READ
Read all
Tax Journal thanks its July 2026 authors
Property 118 Ltd and another v HMRC
Perenco UK Ltd v HMRC
When is a trustee not a trustee?
The end of offshore execution on secondary transactions