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Domicile
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Domicile
DOMICILE
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...
Accuro Trust (Switzerland) SA v HMRC
Foreign property added to excluded property settlement when deemed domiciled is not relevant property
Other cases that caught our eye: 4 April 2025
Determining domicile: In A Weis v HMRC [2025] UKFTT 348 (TC) (21 March), the taxpayer, a Rabbi, had been born in the UK in 1949 in Manchester to a father who had been born in Eastern Europe but had come to the UK in 1938. The father had acquired...
Winners and losers under the non-dom reforms
Emma Chamberlain
Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.
The UK’s non-dom regime: the end of the road?
Dominic Lawrance
Sophie Dworetzsky
Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys)
share their views on the current tax regime for UK resident non-domiciled
individuals and what might happen under a Labour government.
Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence
Claire Weeks
Clare Maurice
Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why
returning to the UK after a period of non-tax residence is not for the faint
hearted.
Domicile disputes: actions speak louder than words
Hugh Gunson
Louise Paterson
With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.
Private client review for September 2023
Kathryn Hart
Edward Reed
Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.
I Strachan v HMRC
Establishing domicile and whether tax loss due to carelessness
Other cases that caught our eye: 7 July 2023
HICBC and discovery assessment powers: There is no sign of the flow of high income child benefit charge (HICBC) cases drying up. HMRC presumably hoped that the retrospective legislation to reverse the decision in Wilkes [2020] UKUT 150 (TCC), where...
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 20 June 2025
Treasury unveils agile approach to tax consultations
HMRC update on capital allowances guidance project
Private school fees VAT challenge fails
HMRC confirm extended deadline for final VAT return
CASES
Read all
Eastern Power Networks plc and others v HMRC
A Moffat and another v HMRC
Performance Leads Ltd v HMRC
Other cases that caught our eye: 20 June 2025
Nellsar Ltd v HMRC
IN BRIEF
Read all
Lessons from Moran on the TOAA rules
IHT excluded property settlements
HMRC’s updated DOTAS guidance
Tax and PISCES
Tax reform and the growth agenda
MOST READ
Read all
Other cases that caught our eye: 13 June 2025
Tax reform and the growth agenda
Solent Pathway Campus Ltd v HMRC
The new UK PE, TP and UTPP rules: key questions
The Government amendments to domestic Permanent Establishment rules