RESIDENCE

Janet Pierce

Thomas Barker and Janet Pierce (Charter Tax Consulting) explain the bad news and good news from the latest condoc on non-dom reforms.

Gary Richards

Gary Richards (Mishcon de Reya) outlines the potential impact of the recent Brisal and KBC Finance Ireland case on the UK, which is complicated by the EU referendum result.

Michael Thomas KC

Michael Thomas (Pump Court Tax Chambers) examines the new legislation in Finance Bill 2016 governing sales of UK land.

Anne Fairpo

The changes in the current Finance Bill will bring rather more intellectual property royalties into the scope of withholding tax, as Anne Fairpo (Temple Tax Chambers) explains.

Santhie Goundar

HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.

Cathya Djanogly

Retention of a home in the UK and residence

Ian Maston

Ian Maston (Mastoni Tax) answers a query on whether a gift of shares in a family company could unintentionally increase the family’s tax burden.

Arabella Murphy

Claire Weeks

Arabella Murphy and Claire Roberts (Maurice Turnor Gardner) answer questions on the recent government consultation, looking at what is proposed, including the reform to non-UK resident trusts.