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Full Description
Booth and Schwarzprovides a crisp analysis of this rapidly developing subject and expertly examines residence and other fiscal connections for individuals, companies and trusts. An established and unrivalled guide For nearly 30 years, this work has provided authoritative, in-depth guidance on the law of residence. This fully revised edition critically analyses the Statutory Residence Test (SRT) for individuals, split year treatment and temporary non-residence including the current HMRC guidance in RDR3. It also provides up-to-date commentary on common law residence and HMRC practice which will remain relevant for years to come. All the updates on tax residence in one place This edition includes comprehensive treatment of the following key topics: . Tax residence of companies, including special rules for CFCs, dual resident investing companies and transfer pricing . Resolution of dual residence . Tribunal jurisdiction and judicial review in residence disputes . Resolving residence disputes and appeals: lessons from Rumbelow v HMRC and Daniel v HMRC . Residence of trusts, estates and partnerships . EU law relating to residence .Residence-related tax compliance under the SRT . Certificates of residence: new HMRC Practice . Latest developments in dual resident company tie-breaker tests in light of the OECD project on Base Erosion and Profit Shifting Quick access to key concepts The accessible style ensures that you can grasp quickly the key underlying concepts of residence, domicile and the related determinants of international taxing jurisdiction for individuals, companies and other entities recognised for tax purposes. Who should read this book? This is an invaluable book for all accountants, lawyers and advisers to individuals and multinational companies. Previous print edition ISBN: 9781780431635
Contents
Chapter 1 United Kingdom taxation Chapter 2 Residence of individualsthe Statutory Residence Test Chapter 3 Residence of individuals: case law test Chapter 4 Ordinary residence Chapter 5 Individuals coming to and departing from the UK Chapter 6 Residence of trusts and estates Chapter 7 Residence of companies Chapter 8 Residence of partnerships Chapter 9 Domicile Chapter 10 Residence, nationality and discrimination in the European Union Chapter 11 Compliance and appeals Appendix 1 HMRC Guidance Note: Statutory Residence Test (SRT): Annex A Appendix 2 HMRC Guidance Note: Statutory Residence Test (SRT): Section 7 Appendix 3 HMRC Statement of Practice SP 1/90 Company Residence
