Managers of hedge funds with operations based in the UK are increasingly concerned changes to the UK tax rules for high earners (50% tax band will be with us from April 2010), combined with EEA restrictions on pay, will make it harder to retain and attract the best talent.
As a result of these trends, becoming non-resident for UK tax purposes enters the conscience of mobile senior employees and other high net worth individuals. However, achieving this where employment and other ties remain here is more difficult than ever but not impossible with the right fact pattern and careful planning. Just how difficult it can be to interpret the rules on loss of UK tax residency was most recently illustrated in the case of Grace v The Commissioners for HM Revenue & Customs 28 October 2009. The case concerned whether Lyle Dicker Grace was resident in the UK for tax pu...
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