Residence & domicile

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état du Grand-Duché de Luxembourg v Lakebrink and another (C-182/06), European Court of Justice, 18 July 2007

ROGER LAWES reconnoitres the new layout of self assessment tax returns

Draft legislation to amend ITEPA 1002, Ch 5

Non domiciles

Jane Kennedy, recently appointed Financial Secretary to the Treasury, confirmed, in answer to an oral question, that the tax status of non domiciles would be kept under 'very close review'. She added in response to another question that 'fairness in the tax system is one of our primary objectives, but it is also important to promote the UK's competitiveness, by remaining an attractive place to do business'.
Taxation's conclusion? It's back on the 'too difficult' pile.

Talotta v Belgian State (Case C-383/05)

JOHN CASSIDY considers what happens now that the offshore disclosure facility registration window has closed

OWEN CLUTTON argues that the new 'permanent establishment' test for trustee residence in TCGA 1992, s 69(2D) is too onerous.

REBECCA MURRAY looks at the new Income Tax Act 2007 provisions relating to the transfer of assets abroad.

REG DAY considers the range of information that is now available to HMRC to check disclosures under the offshore disclosure facility and to target those who do not come forward.

JOHN NUGENT considers tax residence in the Isle of Man for UK individuals and their business interests.

PENNY BATES presents an idiot's guide to the taxation of settlors and beneficiaries of offshore trusts.

KEVIN SLEVIN believes it is time for a fundamental rethink of the rules for non-domiciles and overseas income and gains

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