Residency: ‘distinct break’ from the UK
Despite a recent discussion draft from the OECD, the difficulties of characterisation of termination payments paid to internationally mobile employees are likely to continue, James Hill explains.
Michael Anderson and Samantha Wilson examine the recent High Court ruling on Prudential, the test case in the CFC and dividend GLO.
HMRC has published RDR1: Guidance Note: Residence, Domicile and the Remittance Basis, which replaces the previous guidance in HMRC6 and applies from 6 April 2013. Readers are also referred to the separate guidance in RDR3: Statutory Residence Test.
From Peter Vaines, Squire Sanders, writing in UK Tax Bulletin, September 2013
Peter Vaines explains why if you’re making a claim for private residence relief, you might need to think again.
Jackie Wheaton considers the tax consequences of a company which is resident in more than one country.
Tim Humphries answers a query on taxation of a Canadian individual taking up employment in the UK
Some immediate reaction on the OECD's Action Plan on Base Erosion and Profit Shifting.
Navigate your way through the rules, with William Arrenberg, Casey O’Hara, Richard Harryman, Mike Haynes, David Smith, Steve Wade and Malcolm Finney.