PWC Comments On HMRC Residence Guidance Consultation

by Robin Pilgrim, LawAndTax-News.com, London

19 September 2008

Alex Henderson, tax partner at PricewaterhouseCoopers LLP, has issued a statement in response to the news that HM Revenue and Customs (HMRC) is consulting on the contents, scope and structure of new taxpayer guidance on residence and domicile issues, which it aims to publish by March 2009.

Mr Henderson commented:

"Clarification of the HMRC practice on residence and domicile is much needed and the consultation will be welcomed by all who are currently and potentially affected by them."

“However, the real need is for a proper statutory framework for deciding residence, which takes account of modern living and working conditions. Taxpayers should be taxed by the clear certainty of law, not the relative uncertainty of HMRC practice.”

Sean Drury, international mobility partner, PricewaterhouseCoopers LLP, added:

"This consultation comes at a time when, as a result of the current downturn, businesses are having to think increasingly creatively about how they deploy their global workforce. Moving employees in and out of the UK can be hugely challenging so companies can only benefit from practical clarification that helps unravel the complexities of this process. Clearer guidance would also boost the UK's competitiveness when it comes to attracting the best global talent."

The guidance will supersede existing booklet IR20 which was updated on an interim basis last July. Comments from taxpayers, tax practitioners and representative bodies are sought by December 15, 2008.

HMRC has stated, however, that it does not want comments on the legislation itself, or about HMRC policy or practice on residence and domicile issues.

Recommended