header-logo header-logo

26 June 2009 / Peter Vaines
Issue: 7375 / Categories: Features , Tax
printer mail-detail

Taxing matters

Peter Vaines pays a visit to Hotel California

The long awaited replacement for IR20 has now been received. It is called HMRC6. It is quite similar to IR20 except that it has all been rearranged which makes it rather difficult to compare. The main elements are still there although they are now hedged around with so many disclaimers that it begins to look like a letter of engagement. Why are they so keen to tell us that we cannot rely on their guidance—surely this is the only reason it has been published.

It is surprising that having regard to the critical importance that HMRC places on the concept of a distinct break in all the recent cases on the subject, there is no reference to it anywhere in HMRC6.

They rather over-emphasise that the act of leaving the UK does not mean you will automatically become non resident. After you leave the country, your residence position will be affected by a number of factors which include; the reason you left the UK; what visits you

If you are not a subscriber, subscribe now to read this content
If you are already a subscriber sign in
...or Register for two weeks' free access to subscriber content

MOVERS & SHAKERS

EIP—Stuart Malcolm

EIP—Stuart Malcolm

EIP strengthens Commercial practice with a new partner

Ellisons—Francesca Brown

Ellisons—Francesca Brown

Ellisons welcomes Francesca Brown to Family team

Shakespeare Martineau—Marie Bourke

Shakespeare Martineau—Marie Bourke

Shakespeare Martineau strengthens Sheffield regulatory practice with new hires

NEWS
A wide-ranging Civil Way column highlights developments from insolvency procedure to employment law, but one case stands out for its lessons on bankruptcy, family homes and digital communications
A sprawling Intellectual Property Office battle between House of Fraser and Frasers Property has delivered a masterclass in modern trade mark law
Courts in England and Wales and Singapore are increasingly confronting complex disputes over international child relocation as families become more globally mobile
The government’s long-awaited family law reform consultation could mark a turning point for domestic abuse victims navigating financial remedy proceedings, but significant challenges remain
A new commercial court pilot giving the public access to documents used in hearings, including expert reports, is raising difficult questions about transparency and privacy
back-to-top-scroll