The proposed statutory residence test

The Statutory Residence Test (SRT) proposed in HMRC's consultation document published on 17 June is a little complex, but it has the potential to bed down a reasonable set of rules for the future. The proposals would substantially clarify the evidence that internationally mobile taxpayers need to handle a challenge by HMRC to their residence status. However, they would not wholly eliminate subjective judgments. This is because of the transitional regime, and also because the changes have no impact on treaty tie-breaker provisions. There may be much greater focus on those in future.