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.
Retention of a home in the UK and residence
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.
What can we expect in the forthcoming condoc on non-doms?
Whether PPR available on land
The Jersey government is consulting tax agents on a number of options for changing the tax rules on distributions from Jersey resident companies, including extending the rules to Jersey trustees.
City law firm RPC has said there has been a 29% rise in the number of tax investigations into internationally mobile high earners by HMRC in the last year, and that the firm ‘does not expect any let up in HMRC’s investigations of this class of high earners’.
Peter Jackson (Taylor Wessing) answers a query on the refinancing of a corporate group owning UK property assets.
Andrew Goldstone and Helen Manis (Mishcon de Reya) review the latest developments that matter in the private client arena