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Informationen zum Autor 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 planning and tax disputes involving international issues. He has written Schwarz on Tax Treaties, among other publications, and is consultant editor of Annotated Double Tax Treaties. He is a vice-president of the International Fiscal Association and a visiting Professorial Fellow at the School of Tax Law, Queen Mary College, London University. 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. Vorwort An authoritative, in-depth guidance on the law of residence from one of the leading practitioners in the UK. Zusammenfassung For nearly 30 years, this work has provided authoritative, in-depth guidance on the law of residence, including most recently the Statutory Residence Test. Since the previous 19th Edition, the proposed changes to domicile and deemed domicile legislation, due to be enacted in April 2017, were omitted from the first Finance Bill of 2017 but then re-introduced and backdated in the Finance 2017-19 Bill, published in September 2017.This edition provides detailed analysis of this legislation, with regard to the deemed domicile rules, changes to remittance basis and overseas companies with UK residential property which now come under scope of IHT. It also includes further amendments to deemed domicile for capital gains tax and income tax, in line with the Finance 2017-19 Bill and reflects further changes as a result of the Finance Act 2018.Commentary on important new case law is included, such as: Development Securities (NO 9) Ltd & Ors v Revenue and Customs [2017] UKFTT 565 (TC) (14 July 2017) regarding central management and control Henderson & Ors v Revenue and Customs [2017] UKFTT 556 (TC) (18 July 2017) regarding domicile Mackay v HMRC [2017] TC 05903 regarding ordinary residence Gulliver v HMRC [2017] UKFTT 0222 (TC) regarding domicile disputes procedural issues Trustees of the P Panayi Accumulation & Maintenance Settlements v Commissioners for Her Majesty's Revenue and Customs (Case C-646/15) regarding change of trust residence and EU law. Inhaltsverzeichnis 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 UnionChapter 11 Compliance and appeals Appendix 1 HMRC Guidance Note: Statutory Residence Test (SRT): Annex A Appendix 2 HMRC Guidance Note: Statutory Residence Test (SRT): Section 7 Appendix 3 HMRC Statement of Practice SP 1/90 Company Residence...
