More shades of grey

With reference to the conclusions presented by Sharon Mckie at the end of her article Fifty shades of grey concerning the proposed statutory residence test (SRT) the so-called ‘complexity’ is only necessary because of the lengths that 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 that they accept that for the above reason this is not feasible and they believe that the proposals are most definitely to be welcomed.

While some 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...