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26 June 2009 / Peter Vaines
Issue: 7375 / Categories: Features , Tax
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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

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MOVERS & SHAKERS

Thomson Hayton Winkley—Jordan Wallace

Thomson Hayton Winkley—Jordan Wallace

Thomson Hayton Winkley strengthens family law team

Ward Hadaway—Barnaby Rosenthall

Ward Hadaway—Barnaby Rosenthall

Construction lawyer returns to Ward Hadaway in Teesside role

Bird & Bird—Shahin Baghaei

Bird & Bird—Shahin Baghaei

Bird Bird hires leading legal transformation expert

NEWS
Legal aid deserts leave almost one in four without adequate access to justice
The Solicitors Regulation Authority (SRA) has warned solicitors and law firms that using artificial intelligence does not alter their professional obligations, amid concerns over inaccurate legal material and client confidentiality
From forgotten interest claims to case-management appeals, a string of procedural developments offers useful—and occasionally cautionary—lessons for practitioners

Jonathan Fisher KC highlights that it now accounts for around 40% of criminal offences, with roughly 70% involving technology, and argues that the UK cannot simply prosecute its way out of the problem. Detection, investigation and prosecution all require improvement, while different fraud types demand tailored responses.

How forcefully can a litigant criticise a public authority before robust advocacy crosses the line into unreasonable conduct? 
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