Residence test

With reference to the conclusions presented by Sharon McKie at the end of her article Fifty shares of grey concerning the proposed statutory residence test the so-called ‘complexity’ is only necessary because of the lengths to which many wealthy people will go to try to ensure they can continue to maintain a substantial UK presence while claiming to be non-UK resident for tax purposes.

Although a simple day-count test may be ideologically preferable I have heard several renowned commentators say they accept that for the above reason it is not feasible and they believe the proposals are most definitely to be welcomed.

While those at the margins may have some uncertainty for the far greater number of ordinary people who are moving into or out of the UK such as those moving because of full-time work and those non-residents...