A distinct break ~ the Upper Tribunal decision in HMRC v James Glyn
In a judgment handed down on 12 October 2015, allowing an appeal brought by HMRC, the Upper Tribunal (Tax and Chancery Chamber) has set out useful guidance on the determination of residence under the common law.
In an article first published in the specialist tax magazine Taxation, Rory Cochrane sets out some of the background and the appeal, highlights the importance of the decision in HMRC V James Glyn and deals with key points such as the definition of a distinct break, the concept of 'settled purpose' and the treatment of the IR20 booklet.
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