Severance pays

residence

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The Gaines-Cooper case has opened up the debate on what constitutes residence and domicile, with regard to taxation, and means expatriates need to consider cutting ties with the UK

The rules on UK residence and domicile were recently brought into the spotlight in the case of Robert Gaines-Cooper v HM Revenue & Customs (HMRC) Commissioners. These rules determine the extent to which someone who lives abroad should be taxed in the UK and, in particular, the extent to which an individual can rely on HMRC published guidance. Gaines-Cooper has had a complex lifestyle to say the least. He has for a number of years had residences in the UK, the Seychelles, where he claimed to be resident, and elsewhere. He also has extensive worldwide business interests and spends a conside...

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