Booth and Schwarz ― Residence, Domicile and Uk Taxation

For nearly 30 years, this work has provided authoritative, in-depth guidance on the law of residence, including most recently the Statutory Residence Test. The last (19th) edition of this book was published in September 2016. Since then, the proposed changes to domicile and deemed domicile legislation, enacted in April 2017, was 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 will cover detailed analyses of this legislation, with regard to the deemed domicile rules, and changes to remittance basis and overseas companies with UK residential property which now come under scope of IHT. It will also include further amendments to deemed domicile for capital gains tax and income tax, in line with the Finance 2017-19 Bill, as well as reflecting further changes as a result of the Finance Act 2018. Also included is updated coverage of the OECD Multilateral Instrument regarding dual residence of persons other than individuals. In addition, commentary on important new case law will be 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; and 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. [Subject: Tax Law, UK Law, EU Law]

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.