Tax Residence and Domicile IssuesH M Revenue & Customs have always considered this area to be one of great interest to them and it is particularly relevant with the New Disclosure Opportunity and the Lichtenstein Disclosure Facility being so prominent. H M Revenue & Customs have successfully challenged individuals, companies and others in high profile court cases to determine that although they may have left the UK that are still UK resident for tax purposes. This is one of the most complex areas of UK tax law and one, unfortunately, that many tax inspectors have difficulty with too. This often leads to inappropriate claims by the tax authority leading to considerable tax risk for those involved. Any revision of UK liabilities will also bring into play the question of interest and ever increasing penalties. The rules for non domiciled individuals are similarly complex in this evolving area of law. We have considerable experience in dealing with investigations, enquiries and challenges to the residence and domicile position of individuals and the residence of companies and businesses. Dealing with these types of investigation is challenging and required a depth of knowledge, experience and understanding not only of the technical issued but the methods required to evidence the correct position. Many of us forget that tax inspectors are specialist investigators, those involved in investigating matters of tax residence or domicile are also specialists; often based in Specialist Investigations, Civil Investigation of Fraud or at HMRC’s Centre for Non Residents. They may use their domestic information powers, ask non UK authorities for assistance, utilise the provisions in tax treaties and so on .... you will therefore need specialist help in your corner, fighting for you.
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