Schwarz on Residence and UK Taxation

Schwarz on Residence and UK Taxation cover

Schwarz on Residence and UK Taxation

Description

This title gives the reader authoritative guidance on the legislation dealing with residence and domicile, which will reflect the upcoming changes in this area - the Government has proposed to end the use of domicile as a determinant of tax liability for individuals from 6 April 2025. The remittance basis of taxation will also end. The legal concept of domicile for income tax, capital gains tax and inheritance tax is to be superseded by a series of rules that rely on tax residence to provide a measure of relief for internationally mobile individuals. These changes necessitate a re-write of Booth and Schwarz to reflect this important change in the legislation. The domicile chapter remains in the book but the term has been withdrawn from the title.

Other structural changes include -
- The old chapter 3 (Residence of individuals: case law test) is coming out of the new edition
- Old chapter 5 (Individuals coming to and departing from the UK) will be changed to the NEW chapter 3
- We will move the split year treatment section of chapter 2 to the first part of this NEW chapter 3
- We will edit the table of statutes, cases, and HMRC material to eliminate references to deleted material

Table of Contents

In terms of the contents list, which may change subject to what is in the Finance Act, it may look as follows -

1 - UK Taxation
2 - Residence of Individuals: the Statutory Residence Test
3 - Individuals coming to and departing from the UK (NEW - The sections in chapter 2 on split year treatment paras 2.30 to 2.40 under a heading “SPLIT-YEAR TREATMENT” and para 2.42 (temporary non-residence) under a heading “ TEMPORARY NON-RESIDENCE” should be moved and inserted as the first part of new chapter 3. Please also leave a blank para 3.01 headed “Introduction”. The third part of the chapter will contain the new “RULES FOR FOREIGN INCOME AND GAINS OF INDIVIDUALS BECOMING UK RESIDENT” currently in Part 2, Chapter 1 of the Finance Bill under a heading “NEW RESIDENTS' RELIEF ON FOREIGN INCOME)
4 - Ordinary Residence
5 - Residence of trusts and estates
6 - Residence of Companies
7 - Residence of partnerships
8 - Residence for Stamp Duty Land Tax
9 - Domicile
10 - Compliance and Appeals

Product details

Published 27 Nov 2025
Format Ebook (PDF)
Edition 1st
Extent 352
ISBN 9781526534583
Imprint Bloomsbury Professional
Publisher Bloomsbury Publishing

About the contributors

Author

Jonathan Schwarz

Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC…