Winckworth Sherwood

UK 200 2014 position: 81


Residence for UK tax purposes — the comprehensive statutory residence test from 2013–14

The introduction in the present tax year 2013–14 of a new comprehensive statutory test for residence (SRT) is likely to be of little direct application to many if not most of our readers, who will have been and continue to be very firmly resident (and indeed domiciled — of which more below) in the UK. However, for professional advisers, it is an enormously significant step for Her Majesty’s Revenue & Customs (HMRC) to take. And indeed those who read the financial pages of the press at all regularly will be aware of this initiative.

It would not be appropriate in a Bulletin of this kind to go into very much detail of the new regime, though there will (necessarily) be some of that. What we think will be most useful is to put it into some form of context, to enable our readers to understand why it was needed and what impact it might have. There may always be a member of the family or a friend who is directly affected.

The concepts of residence and, separately domicile, are used to police the UK’s territorial tax boundaries. After all, it would make no sense — and indeed it would lead to significant inter-jurisdiction dispute — for the UK (or indeed other countries) to seek to tax income, gains and assets on a worldwide basis in the hands of those who have no or even a very limited connection with the UK…

If you are registered and logged in to the site, click on the link below to read the rest of the Winckworth Sherwood briefing. If not, please register or sign in with your details below.

Sign in or Register to continue reading this article

Sign in


It's quick, easy and free!

It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.

Register now

Why register to The Lawyer


Industry insight

In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.


Market intelligence

Identify the major players and business opportunities within a particular region through our series of free, special reports.


Email newsletters

Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.

More relevant to you

To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.


Minerva House
5 Montague Close

Turnover (£m): 30.48
No. of lawyers: 117