Full Description
Schwarz on Residence and UK Taxation, 22nd Edition provides a crisp analysis of this constantly developing subject, and expertly examines residence and other fiscal connections for individuals, companies, trusts and partnerships. The accessible style ensures the reader can quickly grasp the key underlying concepts that apply to determine the key territorial connection for UK tax liability.
This fully revised edition critically analyses the wholesale reform of residence and domicile of individuals and related connecting factors in Finance Act 2025. This edition includes comprehensive treatment of the following key topics:
- Resolution of dual residence after Oppenheimer v HMRC and McCabe v HMRC
- Double tax treaty residence of companies in light of the Court of Appeal in G E Financial Investments v HMRC
- Exceptional circumstances for the SRT determined by the Court of Appeal in A v HMRC
- Residence for the additional rate of Stamp Duty Land Tax on non-residents
- Continuing relevance of domicile and domicile disputes
- Residence of trusts, estates and partnerships
- Ordinary residence for National Insurance Contributions
Schwarz on Residence is invaluable for all accountants, lawyers and advisers to individuals and multinational companies.
Jonathan Schwarz FTII is an English, Irish and Canadian Barrister at Temple Tax Chambers and is also a South African Advocate. He focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He has written Schwarz on Tax Treaties among other publications. He is a Visiting Professor at King's College London where he is programme director for the international tax law LLM. He has been listed as a leading tax Barrister in both the Legal 500 and Chambers' UK Bar he is "highly regarded for his expertise in international tax matters" and is lauded for his "brilliant" handling of cross-border tax problems in Who's Who Legal (Lexology).
Contents
Chapter 1 - UK Taxation
Chapter 2 - Residence of Individuals: the Statutory Residence Test
Chapter 3 - Individuals coming to and departing from the UK
Chapter 4 - Ordinary Residence
Chapter 5 - Residence of Trusts and Estates
Chapter 6 - Residence of Companies
Chapter 7 - Residence of Partnerships
Chapter 8 - Residence for Stamp Duty Land Tax
Chapter 9 - Domicile
Chapter 10 - Compliance and Appeals
