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RESIDENCE


Jo Bateson (Mercer & Hole) provides a practical guide to the new regime.
Damien Crossley and Bezhan Salehy (Macfarlanes) examine the Government’s latest policy paper.
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...
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
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.
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.
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).
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) examine what we know now following this week’s policy paper.
In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).
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).
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