Peter Halford (PwC Legal) explains why an onward appeal in the case of Fisher is almost inevitable
Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts
Tax consolidation: non-resident intermediary companies
Priya Dutta answers a query on the tax residency of employees seconded to overseas offices and undertaking training in the UK
Group relief when the link company is non-UK resident
Jackie Wheaton answers a query on whether interest has a UK source, reviewing the key issues following Perrin v HMRC
Peter Stevens summarises the government’s proposals for charging tax on capital gains made by non-residents from disposals of UK residential property
Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed
Peter Vaines comments on the operation of CGT on non-residents and ATED
Non-domiciled taxpayers are paying record amounts of tax on income that they generate in the UK, according to figures obtained by the law firm Pinsent Masons.