Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Residence
Home
Residence
RESIDENCE
Understanding the FIG regime
Jo Bateson
Jo Bateson (Mercer & Hole) provides a practical guide to the new regime.
Carried interest tax reform: next steps
Bezhan Salehy
Damien Crossley
Damien Crossley and Bezhan Salehy (Macfarlanes) examine the
Government’s latest policy paper.
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...
Sajedi: an unwelcome Ramsay surprise
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
Ask an expert: The ‘dog-leg’: a way to fund non-dom divorces while preserving clean capital?
Henry Lowe
Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment
now that the non-dom regime has been abolished.
Ask an expert: Just how enforceable is UK inheritance tax abroad?
Alyssa Haggarty
Claire Weeks
Alyssa Haggarty and Claire Weeks (Maurice Turnor Gardner) consider the
status of the so-called ‘revenue rule’ and the options available to HMRC to
seek assistance in the collection of tax abroad.
Corporate re-domiciliation Panel Report: potential impact on structuring inward bound re-domiciliation
Freddie Schwier
Dominic Foulkes
Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.
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).
Much ado about non-doms: the new policy paper
Lynnette Bober
Helen McGhee
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) examine what
we know now following this week’s policy paper.
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
Go to page
of
16
EDITOR'S PICK
Spare us the cUTTer
Nick Thornton
1 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
2 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
3 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
4 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
5 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
6 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
7 /7
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
NEWS
Read all
Foreign Permanent Establishment exemption to be made mandatory
Chancellor announces package of road fuel measures
Quarterly advisory fuel rates published
New Isle of Man social security agreement signed
Streeting proposes CGT equalisation in ‘wealth tax’ plan
CASES
Read all
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
H Gwyn-Jones v HMRC
Other cases that caught our eye: 29 May 2026
HC-One No 1 Ltd v HMRC
IN BRIEF
Read all
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
The growing problem of the personal allowance phase down
Situs: loan notes
MOST READ
Read all
HC-One No 1 Ltd v HMRC
Take 3.9 TV Partnership and others v HMRC
When Homer nods: the rise of the Inco principle in tax
The growing problem of the personal allowance phase down
Trustees IHT exposure from 6 April 2025