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CHRISTOPHER STONE explains the implications of Gaines-Cooper
v HMRC for non-residence
KEY POINTS
- A brief summary of the two cases.
- IR20 and leaving the UK to work full-time abroad.
- Determining whether a taxpayer has left the UK in other circumstances.
- Has there been a distinct break with the UK?
- The importance of other factors in residence status.
Residence status is an extremely important concept in personal taxation and underpins an individual’s liability to income and capital gains tax.
The Court of Appeal’s judgment in the joined judicial review applications of Gaines-Cooper v HRMC; Davis & James v HMRC [2010] EWCA Civ 83 will have practical application for thousands of people seeking non-resident status.
In a decision on the status and application of IR20 HMRC’S guidance leaflet on residence the court upheld the department’s interpretation of chapter 2 confirming that HMRC had...
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