On 17 June HMRC released its Consultation Document (ConDoc) on the proposed new Statutory Residency Test (SRT), which is expected to be effective from 6 April 2012.
To assist in drafting a clear test several of the old words and phrases have been clearly defined as well as introducing two new important definitions. These are:-
Arriver – Someone coming to the UK who was not resident in the UK for any of the previous 3 years
Leaver – – Someone leaving the UK who was resident in the UK for any of the previous 3 years
The new test is designed in three parts, and works sequentially so once a condition is satisfied and the status is determined then there is no need to progress any further.
It is hoped that a statutory test will give clients and their advisors more certainty when considering this, currently, uncertain area of tax law.
Gabelle works closely with advisers both in the UK and internationally to ensure that their clients understand their exposure to UK tax and can plan their affairs accordingly.
Please contact Paul Bramall on 020 7182 4741 or via email on email@example.com discuss the new proposals and how Gabelle can assist you and/or your clients.