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For many years the guidance on residence in the UK issued by the Revenue (IR20) was taken as having quasi-legal force and leading firms gave advice on this basis.

Recent moves by the Revenue, including in the case of Robert Gaines-Cooper, have ushered in a climate of uncertainty in taxation, which is unwelcome and arguably unfair.

The aim of this page is to provide a forum for the exchange of views and information. Those concerned with the site take no responsibility for any of the views expressed.

Tuesday, June 2, 2009

Plus ça change...

Her Majesty’s Revenue & Customs (HMRC) issued new guidance to replace IR20 from April 6 2009 ( “Residence, Domicile and the Remittance Basis” ).

As with IR20, HMRC emphasises that it is general guidance only on the officials' view of how the rules apply: the facts of individual cases may make the guidance inappropriate. In other words it's business as usual and taxpayers still do not get the clarity they deserve.

It is high time these concepts were defined by statute - the status quo of relying on HMRC to develop them by applying the limited case law in this area is an inadequate solution.

posted by Issues of Domicile | 10:32 AM | 0 Comments