Taxing Matters: The Court of Appeal's decision in A Taxpayer v HMRC with Rebecca Sheldon, Old Square Tax Chambers

In this episode, Alexis Armitage, Taxing Matters host and Senior Associate at RPC, speaks with Rebecca Sheldon of Old Square Tax Chambers, about the Court of Appeal’s recent decision in A Taxpayer v HMRC, in which Rebecca was instructed on behalf of the taxpayer.

The discussion focuses on how "exceptional circumstances" under the Statutory Residence Test (SRT) should be interpreted, particularly where personal and moral obligations are involved.

Join Alexis and Rebecca as they discuss:

• the background of the case and why HMRC challenged the taxpayer’s UK residency status
• the SRT and the meaning of "exceptional circumstances"
• why the taxpayer's claim under the SRT is of particular interest
• the journey of the case through the FTT, the UT and finally the Court of Appeal
• how the case is relevant for other taxpayers seeking to rely on "exceptional circumstances" in the context of the SRT
• the key lessons from the decision for taxpayers and advisors on evidence and planning residency days.

Thank you for listening to this episode. You can listen to and subscribe to Taxing Matters on Apple Podcasts and Spotify and stay up to date with developments in the tax world.

If you would like to discuss any of the matters raised in this episode, or find out more about our tax services, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.