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

NLJ Career Profile: Nikki Bowker, Devonshires

NLJ Career Profile: Nikki Bowker, Devonshires

Nikki Bowker, head of litigation and dispute resolution at Devonshires, on career resilience, diversity in law and channelling Elle Woods when the pressure is on

Ellisons—Sarah Osborne

Ellisons—Sarah Osborne

Leasehold enfranchisement specialist joins residential property team

DWF—Chris Air

DWF—Chris Air

Firm strengthens commercial team in Manchester with partner appointment

NEWS
Contract damages are usually assessed at the date of breach—but not always. Writing in NLJ this week, Ian Gascoigne, knowledge lawyer at LexisNexis, examines the growing body of cases where courts have allowed later events to reshape compensation
The Supreme Court has restored ‘doctrinal coherence’ to unfair prejudice litigation, writes Natalie Quinlivan, partner at Fieldfisher LLP, in this week' NLJ
The High Court’s refusal to recognise a prolific sperm donor as a child’s legal parent has highlighted the risks of informal conception arrangements, according to Liam Hurren, associate at Kingsley Napley, in NLJ this week
The Court of Appeal’s decision in Mazur may have settled questions around litigation supervision, but the profession should not simply ‘move on’, argues Jennifer Coupland, CEO of CILEX, in this week's NLJ
A simple phrase like ‘subject to references’ may not protect employers as much as they think. Writing in NLJ this week, Ian Smith, barrister and emeritus professor of employment law at UEA, analyses recent employment cases showing how conditional job offers can still create binding contracts
back-to-top-scroll