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Schwarz on Residence and UK Taxation, 22nd Edition provides a crisp analysis of this constantly developing subject, and expertly examines residence and other fiscal connections for individuals, companies, trusts and partnerships. The accessible style ensures readers can quickly grasp the key underlying concepts that apply to determine the key territorial connection for UK tax liability.
This fully revised edition critically analyses the wholesale reform of residence and domicile of individuals and related connecting factors in Finance Act 2025. This edition includes comprehensive treatment of these key topics:
- Resolution of dual residence after
Oppenheimer v HMRC and
McCabe v HMRC- Double tax treaty residence of companies in light of the Court of Appeal in
G E Financial Investments v HMRC- Exceptional circumstances for the SRT determined by the Court of Appeal in
A v HMRC - Residence for the additional rate of Stamp Duty Land Tax on non-residents
- Continuing relevance of domicile and domicile disputes
- Residence of trusts, estates and partnerships
- Ordinary residence for National Insurance Contributions
Schwarz on Residence is invaluable for all accountants, lawyers and advisers to individuals and multinational companies.
List of contents
Chapter 1 - UK Taxation
Chapter 2 - Residence of Individuals: the Statutory Residence Test
Chapter 3 - Individuals coming to and departing from the UK
Chapter 4 - Ordinary Residence
Chapter 5 - Residence of Trusts and Estates
Chapter 6 - Residence of Companies
Chapter 7 - Residence of Partnerships
Chapter 8 - Residence for Stamp Duty Land Tax
Chapter 9 - Domicile
Chapter 10 - Compliance and Appeals
About the author
Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is the author of Schwarz on Tax Treaties (CCH) and Booth and Schwarz: Residence, Domicile and UK Taxation 16th Edition (Bloomsbury) among other publications and a contributor to Transfer Pricing and Business Restructurings: Streamlining all the way (IBFD). He is a visiting Professor at the Faculty of Law, King’s 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. The Legal 500 has commented that ‘Jonathan Schwarz is a client favourite, particularly for international transactions.’ In the Chambers 2011 he is commended for his ‘encyclopaedic knowledge of double tax treaties’. See www.taxbarristers.com for details.
