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26 June 2009 / Peter Vaines
Issue: 7375 / Categories: Features , Tax
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Taxing matters

Peter Vaines pays a visit to Hotel California

The long awaited replacement for IR20 has now been received. It is called HMRC6. It is quite similar to IR20 except that it has all been rearranged which makes it rather difficult to compare. The main elements are still there although they are now hedged around with so many disclaimers that it begins to look like a letter of engagement. Why are they so keen to tell us that we cannot rely on their guidance—surely this is the only reason it has been published.

It is surprising that having regard to the critical importance that HMRC places on the concept of a distinct break in all the recent cases on the subject, there is no reference to it anywhere in HMRC6.

They rather over-emphasise that the act of leaving the UK does not mean you will automatically become non resident. After you leave the country, your residence position will be affected by a number of factors which include; the reason you left the UK; what visits you make the UK after you have left; what connections you

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MOVERS & SHAKERS

Jurit LLP—Caroline Williams

Jurit LLP—Caroline Williams

Private wealth and tax team welcomes cross-border specialist as consultant

Freeths—Michelle Kirkland Elias

Freeths—Michelle Kirkland Elias

International hospitality and leisure specialist joins corporate team as partner

Flint Bishop—Deborah Niven

Flint Bishop—Deborah Niven

Firm appoints head of intellectual property to drive northern growth

NEWS
Talk of a reserved ‘Welsh seat’ on the Supreme Court is misplaced. In NLJ this week, Professor Graham Zellick KC explains that the Constitutional Reform Act treats ‘England and Wales’ as one jurisdiction, with no statutory Welsh slot
The government’s plan to curb jury trials has sparked ‘jury furore’. Writing in NLJ this week, David Locke, partner at Hill Dickinson, says the rationale is ‘grossly inadequate’
A year after the $1.5bn Bybit heist, crypto fraud is booming—but so is recovery. Writing in NLJ this week, Neil Holloway, founder and CEO of M2 Recovery, warns that scams hit at least $14bn in 2025, fuelled by ‘pig butchering’ cons and AI deepfakes
After Woodcock confirmed no general duty to warn, debate turns to the criminal law. Writing in NLJ this week, Charles Davey of The Barrister Group urges revival of misprision or a modern equivalent
Family courts are tightening control of expert evidence. Writing in NLJ this week, Dr Chris Pamplin says there is ‘no automatic right’ to call experts; attendance must be ‘necessary in the interests of justice’ under FPR Pt 25
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