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

Quinn Emanuel Urquhart & Sullivan—Andrew Savage

Quinn Emanuel Urquhart & Sullivan—Andrew Savage

Firm expands London disputes practice with senior partner hire

Druces—Lisa Cardy

Druces—Lisa Cardy

Senior associate promotion strengthens real estate offering

Charles Russell Speechlys—Robert Lundie Smith

Charles Russell Speechlys—Robert Lundie Smith

Leading patent litigator joins intellectual property team

NEWS
The government’s plan to introduce a Single Professional Services Supervisor could erode vital legal-sector expertise, warns Mark Evans, president of the Law Society of England and Wales, in NLJ this week
Writing in NLJ this week, Jonathan Fisher KC of Red Lion Chambers argues that the ‘failure to prevent’ model of corporate criminal responsibility—covering bribery, tax evasion, and fraud—should be embraced, not resisted
Professor Graham Zellick KC argues in NLJ this week that, despite Buckingham Palace’s statement stripping Andrew Mountbatten Windsor of his styles, titles and honours, he remains legally a duke
Writing in NLJ this week, Sophie Ashcroft and Miranda Joseph of Stevens & Bolton dissect the Privy Council’s landmark ruling in Jardine Strategic Ltd v Oasis Investments II Master Fund Ltd (No 2), which abolishes the long-standing 'shareholder rule'
In NLJ this week, Sailesh Mehta and Theo Burges of Red Lion Chambers examine the government’s first-ever 'Afghan leak' super-injunction—used to block reporting of data exposing Afghans who aided UK forces and over 100 British officials. Unlike celebrity privacy cases, this injunction centred on national security. Its use, the authors argue, signals the rise of a vast new body of national security law spanning civil, criminal, and media domains
back-to-top-scroll