• Type: Publication series
  • Date: 11/14/2013

United Kingdom – Capital Gains and Residence Case Emphasizes Importance of Record-Keeping 

KPMG LLP in the U.K. reports on a decision by the First Tier Tribunal (FTT) in a case concerning an appeal against assessments issued by HM Revenue & Customs (HMRC) to the appellants for capital gains tax payable for each of the four years ending April 5, 2005. The assessments were issued on the basis that the appellants had remained U.K. resident throughout the tax years in question. Although the case involved a review of the law in force prior to the introduction of the U.K. Statutory Residence Test (“SRT”) in April 2013, it highlights the importance of good record-keeping by taxpayers in matters concerning residence. This is still relevant for all taxpayers, even after the change in legislation regarding the SRT.


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