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Statutory residence test
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Statutory residence test
STATUTORY-RESIDENCE-TEST
Disregarding SRT days: common sense prevails in Parker
Emily Osborne
‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.
M Parker v HMRC
Statutory residence: transit exemption and exceptional circumstances
A Taxpayer v HMRC
Court of Appeal decides moral obligations can be part of ‘exceptional circumstances’ for statutory residence test.
Home and away: how to go non-resident after McCabe
Oliver Marre
The Upper Tribunal’s decision in McCabe shows how difficult it can be to
challenge findings of fact when confronted with multi-factorial tests, writes
Oliver Marre (5 Stone Buildings).
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).
A tax on conscience? A moral dilemma for non-residents
Liam McKay
Robert Waterson
The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).
The statutory residence test: an exceptionally useful case on ‘exceptional circumstances’
Dominic Lawrance
Catrin Harrison
Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.
UK residence: exceptional days
Peter Vaines
HMRC comes to the rescue.
Private client briefing for September 2016
Natalie Quail
Andrew Goldstone
Andrew Goldstone and Natalie Quail (Mishcon de Reya) review the latest tax developments affecting private clients, including the three key consultations.
Importation of private aircraft into the EU by a non-EU resident
Andre Anthony
Andre Anthony (CMS Cameron McKenna) explains the tax issues arising on the importation of a private jet into the EU by a non-EU resident.
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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
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CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
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Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
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Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
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Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer