Taxation U.K.

Booth and Schwarz: Residence, Domicile and UK Taxation, 17th edition

By Jonathan Schwarz
Bloomsbury Professional (formerly Tottel Publishing) September 2013

Specifications

ISBN-13
9781780431635
Publisher
Bloomsbury Professional (formerly Tottel Publishing)
Publication
September 2013
Format
Paperback
Jurisdiction
U.K. ? Countri(es) for reference only

Details

Booth & Schwarz: Residence, Domicile and UK Taxation, 17th Edition provides a crisp analysis of this rapidly developing subject and expertly examines residence and other fiscal connections for individuals, companies and trusts.

Detailed analysis of the Statutory Residence Test

For nearly 30 years, this work has provided authoritative, in-depth guidance on the law of residence. The Statutory Residence Test (SRT) for individuals in Finance Act 2013 is the most significant development in determining international taxing jurisdiction since the introduction of income tax in 1799.

This fully revised edition critically analyses the new SRT for individuals, split year treatment and temporary non-residence. It also provides up-to-date commentary on common law residence and HMRC practice which will remain relevant for years to come.

This edition offers comprehensive coverage of the following key topics:
• Resolution of dual residence in light of Yates v HMRC
• Tax residence of companies including special rules for CFCs, dual resident investing companies and transfer pricing
• Tribunal jurisdiction in residence disputes after the Court of Appeal ruling in Daniel v HMRC
• Resolving residence disputes and appeals
• Residence of trusts, estates and partnerships
• EU law relating to residence
• Residence-related tax compliance under the SRT

 

Booth & Schwarz: Residence, Domicile and UK Taxation is an invaluable book for all accountants, lawyers and advisers to individuals and multinational companies.

Table of Contents

Chapter 1: United Kingdom taxation;
Chapter 2: Residence of individuals: the Statutory Residence Test;
Chapter 3: Residence of individuals: Case law test;
Chapter 4: Ordinary residence;
Chapter 5: Individuals coming to and departing from the UK;
Chapter 6: Residence of trusts and estates;
Chapter 7: Residence of companies;
Chapter 8: Residence of partnerships;
Chapter 9: Domicile;
Chapter 10: Residence, nationality and discrimination in the European Union;
Chapter 11: Compliance and appeals;
Appendix 1: HMRC RDR 3 Annex 1;
Appendix 2: HMRC Statement of Practice SP 1/90.

About the Author

Jonathan Schwarz FTII is a Barrister at Temple Tax Chambers and is also a South African and a Canadian lawyer. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He has written Schwarz on Tax Treaties among other publications. He is a Visiting Professor at the Faculty of Law, King’s College, London where he is programme leader for the LLM in international tax law. He has been listed as a leading tax Barrister in both the Legal 500 by reference to recommendation for international corporate tax, and Chambers’ Guide to the Legal Profession by reference to international transactions and particular expertise in transfer pricing.

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