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.
Only logged in members who have access to, or have purchased this product may leave a review.