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Home
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RESIDENCE
The statutory residence test: ten things we find very difficult about you
Claire Weeks
Aoife McCauley
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).
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Other cases that caught our eye: 19 January 2024
The meaning of ‘residence’ for LBTT purposes: A Blue v Revenue Scotland [2023] FTSTC 4 (21 December 2023) is a case on the additional dwelling supplement rules for Scottish land and buildings transaction tax, particularly the rules relating to...
Why constructive ambiguity is sometimes the best policy
Jeremy Mindell
Jeremy Mindell (Primondell) believes that judicial interpretation of existing
legislation is preferable to a wholesale codification of the law that would
become outdated and easy to manipulate.
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Jersey’s economic substance rules
Rupert Lee
Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.
Private client review for April 2020
Andrew Goldstone
Moustapha Hammoud
Andrew Goldstone and Moustapha Hammoud (Mishcon de Reya) provide a
monthly update.
UK residence: exceptional days
Peter Vaines
HMRC comes to the rescue.
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
Test-Chancellor outlines financial services strategy
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
One minute with... Charlie Friend