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Fifty shades of grey

03 July 2012 / Sharon McKie
Issue: 4360 / Categories: Comment & Analysis , residence test , Residence & domicile
SHARON McKIE scrutinises the proposed statutory residence test


  • Automatic residence.
  • The midnight rule.
  • No definition of ‘home’.
  • What are sufficient ties?
  • Test is complex.

If one were considering what books to pack for summer holiday reading one attractive option might be the government’s response to the June 2011 consultation on the statutory definition of tax residence and reform of ordinary residence together with proposed draft legislation.

The published legislation in relation to the statutory residence test is said to be ‘close to a final draft subject to any changes that may be considered as a result of [the] consultation’. The legislation is split into four parts:

  • Part I – the main rules of the test;
  • Part II – key concepts and definitions;
  • Part III...

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