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KEITH M GORDON may be persuaded of the benefits of a statutory residence test
KEY POINTS
- No retrospection for the new test from April 2012.
- Changes to the rules on counting days.
- When will a taxpayer definitely be treated as resident in the UK?
- Using ‘connecting factors’ to determine residence status.
I should start this article with a confession: I was originally a silent member of the camp that opposed a statutory residence test (StaRT).
This was not because I couldn’t see the advantages that the promised certainty would provide for taxpayers (and therefore UK plc) but simply because I was concerned that the price of this certainty would be too high for comfort.
However particularly after the disappointing outcomes in LD Grace v HMRC (No 2) [2011] UKFTT 36 and A Tuczka v HMRC [2011] UKUT 113 (and having seen HMRC’s arguments in
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