Test

On 8 May 2013, the U.K. tax authorities, HM Revenue and Customs (“HMRC”), published the much-anticipated draft guidance to the new statutory residence test (SRT)1. As expected, the guidance is detailed and contains many examples. The guidance provides a helpful look at HMRC’s view of implementation plans for the SRT, but significant complexity and...

On 8 May 2013, the U.K. tax authorities, HM Revenue and Customs (“HMRC”), published the much-anticipated draft guidance to the new statutory residence test (SRT)1. As expected, the guidance is detailed and contains many examples. The guidance provides a helpful look at HMRC’s view of implementation plans for the SRT, but significant complexity and...

On 8 May 2013, the U.K. tax authorities, HM Revenue and Customs (“HMRC”), published the much-anticipated draft guidance to the new statutory residence test (SRT)1. As expected, the guidance is detailed and contains many examples. The guidance provides a helpful look at HMRC’s view of implementation plans for the SRT, but significant complexity and...

H.M. Treasury announced in a “Written Ministerial Statement” (WMS) that the proposed legislation on a U.K. statutory residence test will be delayed until the Finance Bill 2013 and implementation delayed until 6 April 2013.1 Background In June 2011,...