Thursday 22 October 2009

Non-resident? HMRC 6

HMRC 6 is the replacement to the IR20 booklet and sets out the criteria for determining whether or not an individual is UK resident for tax purposes. The main innovation is the removal of day counting and the introduction of the "Factors ". The only time when only day counting will be used is the 183 day rule. HMRC is attempting to take away the perceived certainty of the day counting and replace it with a vague set of Factors which need to be considered before it is accepted that someone is non resident. This means that it is no longer good enough for individuals to simply, for example, avoid spending 90 days per annum in the UK to avoid being UK resident. HMRC will look at other Factors (such as available accommodation). This is clearly unsatisfactory for taxpayers as it is difficult to predict what the outcome will be in each case. Follow the links for more information Thomas Eggar HMRC (page 15).

No comments:

Post a Comment