Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.
In light of the judgment, Patricia Mock and Bill Dodwell look at what it means for HMRC powers regarding extra-statutory concessions and contending residency, and legitimate expectation
Tax experts who have been calling for a statutory definition of ‘residence’ for many years have welcomed proposed reforms but flagged a number of issues to be addressed.
Carolyn Steppler reviews the proposed changes to the remittance rules
Heather Gething and Rupert Shiers examine the proposed three-part test
Amanda Sullivan provides your at-a-glance guide
A double taxation convention between the UK and Germany, signed in March 2010, entered into force on 30 December 2010 (see SI 2010/2975).
The revised version of HMRC’s guide to Residence, Domicile and the Remittance Basis, is now available.