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Work still has to be done on the the statutory residence test to provide certainty
KEY POINTS
- Problems with the full-time working overseas test.
- Definition of a home in the UK.
- Country state or territory.
- Split-year cases.
This article was written before the publication of the Finance Bill.
The Finance Bill 2013 after receiving royal assent will bring into effect the new statutory residence test (SRT) for individuals and the demise of the longstanding HMRC6 as well as extra-statutory concessions D2 A11 and A78.
For tax practitioners HMRC and the courts a whole new world of uncertainty ambiguity and no doubt frustration opens up before us.
The test was intended to be concise clear and unambiguous such that the famous man on the Clapham omnibus would be able to work out for himself the answer to the simple question: “Am I resident...
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