header-logo header-logo

Taxing Matters

21 June 2007 / Peter Vaines
Issue: 7278 / Categories: Features , Tax
printer mail-detail

DOMICILE MATTERS >>
THE MEANING OF A QUALIFIED CORPORATE BOND >>
MITIGATED PENALTIES >>

DOMICILE RULINGS

Many people will be aware of the difficulties which have arisen in obtaining a domicile ruling from HM Revenue & Customs (HMRC). If an individual wants to know where he is domiciled, he has to seek professional advice because HMRC will not engage in correspondence on the matter.

Not that it gave formal rulings anyway—but obtaining its view was pretty valuable. HMRC takes the—not altogether unreasonable—view that it will only consider the matter if there is a tax liability dependent upon it. For a UK resident, this is not a problem; if he has foreign income he can explain on his tax return that this income is not taxable because it has not been remitted and he can tick the relevant boxes claiming to be domiciled abroad.

However, there are many people who are not UK resident and do not submit tax returns but who are still concerned about their domicile because that is what determines their liability to inheritance tax.

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

Birketts—trainee cohort

Birketts—trainee cohort

Firm welcomes new cohort of 29 trainee solicitors for 2025

Keoghs—four appointments

Keoghs—four appointments

Four partner hires expand legal expertise in Scotland and Northern Ireland

Brabners—Ben Lamb

Brabners—Ben Lamb

Real estate team in Yorkshire welcomes new partner

NEWS
Robert Taylor of 360 Law Services warns in this week's NLJ that adoption of artificial intelligence (AI) risks entrenching disadvantage for SME law firms, unless tools are tailored to their needs
The Court of Protection has ruled in Macpherson v Sunderland City Council that capacity must be presumed unless clearly rebutted. In this week's NLJ, Sam Karim KC and Sophie Hurst of Kings Chambers dissect the judgment and set out practical guidance for advisers faced with issues relating to retrospective capacity and/or assessments without an examination
Delays and dysfunction continue to mount in the county court, as revealed in a scathing Justice Committee report and under discussion this week by NLJ columnist Professor Dominic Regan of City Law School. Bulk claims—especially from private parking firms—are overwhelming the system, with 8,000 cases filed weekly
Charles Pigott of Mills & Reeve charts the turbulent progress of the Employment Rights Bill through the House of Lords, in this week's NLJ
From oligarchs to cosmetic clinics, strategic lawsuits against public participation (SLAPPs) target journalists, activists and ordinary citizens with intimidating legal tactics. Writing in NLJ this week, Sadie Whittam of Lancaster University explores the weaponisation of litigation to silence critics
back-to-top-scroll