As Robert Gaines-Cooper finally loses his appeal in his long running battle with the Revenue to establish that he ceased to be UK resident almost 20 years ago, attention is now turning to the proposed new statutory residency test due to come into effect in April 2012.
Commenting on the Gaines-Cooper appeal loss, Geoffrey Todd, a private client and tax partner at law firm Boodle Hatfield said: “This case illustrates the difficulty some internationally mobile taxpayers have had in recent years in determining their residence position. It could be regarded as largely of historical interest since IR20 has been replaced by new guidance in the form of HMRC6, and in April next year the UK will have a statutory residence test, largely based on simpler day-counting tests." "However we will not be entirely free of the old rules, since the new test will retain so...
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