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residence & domicile
EC formal request for the UK to amend its anti-avoidance legislation
On 6 December it was announced that the UK is planning to change two key anti-avoidance provisions: the rules governing transfers of assets abroad and the attribution of gains made by non-resident companies. Apparently proposals will be published for consultation around the time of Budget 2012...
Statutory Residence Test Postponed
The Government has issued the draft Finance Bill today with a number of other documents and announcements. A key – and somewhat disappointing announcement is that the new statutory residence test will not now come in to force until 2013/14 – a year later than we had hoped. The...
UK-Swiss Tax Agreement
There has been a lot of press coverage recently concerning this historic agreement designed to combat offshore tax evasion. This note sets out the main points of the agreement which was formally signed on 6 October and will come into force on 1 January 2013. The Basics The agreement will affect...
Gaines Cooper - a Long and Winding Road comes to an end
Accountancy Age is reporting on Twitter that Mr Gaines Cooper has lost in the Supreme Court. The judgement was not unanimous and the dissenting judge argued that the necessity for a clean break should have been clearly expressed.
US relief for the remittance basis charge confirmed
It is reported that the remittance basis charge is accepted as being relievable against US tax. Since its introduction in 2008, it was unclear whether the remittance basis charge of £30,000 was creditable in the US meaning that many US taxpayers felt unable to claim the remittance basis in the UK...
