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Wednesday, December 23, 2020
HMRC v Development Securities, the Court of Appeal (the “
CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and controlled in the UK.
While of considerable interest, it should be remembered that the question of where a company is centrally managed and controlled is principally one of fact and so different facts might yield a different conclusion.
What the CA’s decision shows is that the line between non-UK and UK residence can be a fine one when it depends on whether the overseas company’s directors gave due consideration to the transaction as a whole or just to a small element of it, and that, accordingly, non-UK company boards should always make sure that they give proper consideration to the transaction as a whole, albeit informed by advice or recommendations th
Online applications can be made from January 1 and the process takes around two weeks
23 December 2020
By Connexion journalist
Obtaining a visa is now applicable to all Britons wishing to move to France or to visit for more than three months.
The site
france-visas.gouv.fr is due to accept applications from January 1 and these should be made no more than three months before a trip. The process takes around 10-15 days.
Issuing visas in the UK is carried out by the French consular service, but a third-party service provider, TLScontact Royaume-Uni, collects application information and, after officials process it, returns the passport with the visa.
Foreign direct investment involving UK companies
Foreign direct investment involving UK companies: 2019
Investment of UK companies abroad (outward) and foreign companies into the UK (inward), including investment flows, positions and earnings, by country, component and industry.
Contact:
1. Main points
The value of inward foreign direct investment earnings fell in 2019 (£43.8 billion) compared with 2018 (£75.2 billion); this decrease (£31.4 billion) was much larger than the fall in outward earnings (£2.4 billion) over the same period.
The much larger fall in the value of inward than outward earnings saw the value of net FDI earnings (outward less inward) in 2019 increase to the highest value since 2011.
Inward FDI earnings with the EU accounted for the greatest proportion of the overall decrease between 2018 and 2019; followed by earnings with the Americas and Asia.
Tax
How does an individual become taxable in your jurisdiction?Principal factors
An individual’s place of domicile and residence are the principal factors in determining how he or she may be taxed in the United Kingdom (UK). The situs of assets will also be relevant in respect of certain taxes.
Domicile
Broadly speaking, an individual’s domicile is where he or she has a ‘permanent home’ and intends to live permanently or indefinitely. Long-term residence may be a factor in determining domicile but is insufficient in itself.
At birth, an individual’s domicile of origin will be based on the domicile of his or her parents (primarily his or her father). A domicile of origin can be displaced by the acquisition of a domicile of dependency (if an individual’s parents acquire a new domicile while he or she is under 16 years) or, after the age of 16 years, a domicile of choice (if an individual resides in another country with the intention of residing there permanently or i