Overview

Schwarz on Residence and UK Taxation, 22nd Edition provides a crisp analysis of this constantly developing subject, and expertly examines residence and other fiscal connections for individuals, companies, trusts and partnerships. The accessible style ensures readers can quickly grasp the key underlying concepts that apply to determine the key territorial connection for UK tax liability. This fully revised edition critically analyses the wholesale reform of residence and domicile of individuals and related connecting factors in Finance Act 2025. This edition includes comprehensive treatment of these key topics: - Resolution of dual residence after Oppenheimer v HMRC and McCabe v HMRC - Double tax treaty residence of companies in light of the Court of Appeal in G E Financial Investments v HMRC - Exceptional circumstances for the SRT determined by the Court of Appeal in A v HMRC - Residence for the additional rate of Stamp Duty Land Tax on non-residents - Continuing relevance of domicile and domicile disputes - Residence of trusts, estates and partnerships - Ordinary residence for National Insurance Contributions Schwarz on Residence is invaluable for all accountants, lawyers and advisers to individuals and multinational companies.

Full Product Details

Author:   Jonathan Schwarz (Temple Tax Chambers)
Publisher:   Bloomsbury Publishing PLC
Imprint:   Bloomsbury Professional
Edition:   22nd edition
ISBN:  

9781526534590

ISBN 10:   1526534592
Pages:   352
Publication Date:   27 November 2025
Audience:   Professional and scholarly ,  Professional & Vocational
Format:   Paperback
Publisher's Status:   Forthcoming
Availability:   Manufactured on demand  

Table of Contents

In terms of the contents list, which may change subject to what is in the Finance Act, it may look as follows - 1 - UK Taxation 2 - Residence of Individuals: the Statutory Residence Test 3 - Individuals coming to and departing from the UK (NEW - The sections in chapter 2 on split year treatment paras 2.30 to 2.40 under a heading “SPLIT-YEAR TREATMENT” and para 2.42 (temporary non-residence) under a heading “ TEMPORARY NON-RESIDENCE” should be moved and inserted as the first part of new chapter 3. Please also leave a blank para 3.01 headed “Introduction”. The third part of the chapter will contain the new “RULES FOR FOREIGN INCOME AND GAINS OF INDIVIDUALS BECOMING UK RESIDENT” currently in Part 2, Chapter 1 of the Finance Bill under a heading “NEW RESIDENTS’ RELIEF ON FOREIGN INCOME) 4 - Ordinary Residence 5 - Residence of trusts and estates 6 - Residence of Companies 7 - Residence of partnerships 8 - Residence for Stamp Duty Land Tax 9 - Domicile 10 - Compliance and Appeals

Reviews

Author Information

Jonathan Schwarz FTII is an English, Irish and Canadian Barrister at Temple Tax Chambers and is also a South African Advocate. He focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He has written Schwarz on Tax Treaties among other publications. He is a Visiting Professor at King’s College London where he is programme director for the international tax law LLM. He has been listed as a leading tax Barrister in both the Legal 500 and Chambers’ UK Bar he is “highly regarded for his expertise in international tax matters.”

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