HMRC’s recently published proposals for the introduction of a deemed UK domicile status.
Walking through the new P85 of statutory residence questions
Work still has to be done on the the statutory residence test to provide certainty
MALCOLM FINNEY explains the continuing interest of the Inland Revenue in investigating offshore captive insurance companies.
FOR AS LONG as I can remember, offshore captive insurance companies owned by United Kingdom interests have been a prime target for investigation by one or more arms of the Inland Revenue. Such investigations have been premised upon the simple belief that captives are a hard-core tax avoidance device; as a consequence, they deserve to be 'attacked' one way or another.