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Brett R

HMRC Enquiry & Treaty Residence Analysis

Brett came to us having received an enquiry into an earlier year tax return prepared by another firm.

The return incorrectly identified him as a UK tax non-resident for the year in question, and, because he had returned to the UK twelve months later (having not been out of the UK for a full tax year), split year treatment was not available to him.

This would mean that Brett’s worldwide income would fall within the scope of UK tax and create a tax liability in excess of £7,800 after considering any allowable foreign tax credits on his overseas employment income.

However, Brett’s original intention was to permanently relocate to Australia, and therefore we were able to argue that he was treaty resident in Australia during this period (supported by evidence maintained by Brett) and therefore no liability was owing to HMRC.
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We are a firm of UK tax advisors with specific expertise in UK tax regulations for those with financial interests both in the UK and abroad.
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