Taxation of Non-residents and Foreign Domiciliaries: Resource Archive

This is a free resource containing reference material referred to in my Taxation of Foreign Domiciliaries and Non-residents which is not widely available. I am very grateful to authors and publishers for permission to put it on this website. The material is not guaranteed to be error free, either in content or in its presentation. On the contrary, I guarantee it will contain some errors! I hope that these will not spoil the general usefulness of this resource for those wishing to research the law in more detail, but no responsibility is accepted for its use.

Case Law

• AG v Bouwens (zip archive)
• AG v Higgins (zip archive)
• Braybrooke v Attorney General
• CH Pte Lt v Comptroller of Income Tax (Supreme Court of Singapore)
• CIR v Lever Bros [1946] AD 441, 14 SATC 1 (zip archive)
• CIR v Philips Gloeilampenfabrieken (zip archive)
• Commissioner of Taxation v Spotless Services Ltd (Court of Appeal of Victoria)
• FGP v Union of India
• G v G
• Inland Revenue v Clark's Trustees
• Minister of National Revenue v Trans-Canada Investment Corp. Ltd.
• TLD Ltd v Commissioner for the South African Revenue Service
• Wahl v Attorney-General (1932) 147 LT 382

HMRC and HM Treasury Documents

• HMRC6: comparison of Jan 2011 and previous version
• HMRC6: comparison of November 2011 and previous version
• Tax Treatment of interest paid by companies to non-residents: Note by Inland Revenue November 1968
• Treasury-IR correspondence: source of interest (1969)
• Tax Treatment of Interest paid by Companies to Non-residents (IR Consultative Document (1983)
• Trusts Consultative Document 1991 chapter 10 (trust residence)
• DTA avoidance technical note
• HM Treasury and Inland Revenue: Reviewing the residence and domicile rules as they affect the taxation of individuals: a background paper (April 2003)

Other References

• John Avery Jones: Taxing Foreign Income from Pitt to the Tax Law Rewrite-the Decline of the Remittance Basis
• Background Paper on Residence & Domicile (2003): CIOT Response
• Background paper on Residence & Domicile (2003): STEP Response
• Michael Bratman: Intentions, Plans, and Practical Reason
• Sir Kenneth Diplock, The Courts as Legislators; presidential address to the Holdsworth Club 1965
• Employment Income Schedule E years before 2003/2004
• The Family Home: years before 2003/2004
• German and UK Swiss Tax Agreements Comparison
• HMRC Qs and As on FA 2008, Dec 2008: Text to follow
• HMRC Qs and As on FA 2008, Jan 2009
• HMRC Qs and As on FA 2008, Mar 2009: Text to follow
• IHT Terminology: Introduction
• Pakistan/UK IHT Double Taxation Arrangement (extract from original published version 1957)
• Royal Commission on the Taxation of Profits and Income (1955) chapter 14 (Residence and Domicile)
• Royal Commission on the Taxation of Profits and Income (1955) comments on what is a trade
• Taxation Practitioner April 1996 page 25
• TFD 10th ed para 45.30 - Rebasing: HMRC example 2
• Vestey: Royal Commission evidence and ensuing debate

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