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.

Hosted on Acast. See acast.com/privacy for more information.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Jonathan Davey KC, of Wilberforce Chambers, one of the UK’s leading barristers in commercial chancery work with a particular focus on tax, trusts and property.

Jonathan shares his practical insights and top tips for navigating the complexities of tax litigation, drawing on decades of experience at the Bar; from keeping cases simple and crafting compelling narratives, to mastering the detail of documentary evidence and knowing when to settle.

Whether you are a tax advisor, litigator, or in-house counsel, this episode offers useful tips for anyone involved in tax disputes and litigation against HMRC.

If you would like to discuss any of the matters raised in this episode, or find out more about our tax litigation offering, 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.

Hosted on Acast. See acast.com/privacy for more information.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Simon Reed, Director and wealth manager at RBC Brewin Dolphin, and head of the Entertainment, Media & Sports client segment in London. Together, they delve into the unique financial challenges faced by clients in the creative industries, including actors, musicians, and digital creators.

Join Alexis and Simon in this month's episode as they discuss:

• the complexities of managing unpredictable income streams
• the importance of early wealth planning for creatives
• working collaboratively with tax lawyers and accountants on cross-border and residency issues
• protecting and monetising intellectual property (IP)
• emerging trends in long-term financial planning, including pensions, succession, and philanthropy
• the rise of new client types in the digital creator economy and their distinct advisory needs.

Whether you advise creatives or are part of the entertainment sector yourself, this episode offers practical insights on how to navigate wealth management and maximise after-tax returns in a rapidly evolving industry.

Our Tax, Investigations and Financial Crime team advise individuals and businesses on a range of complex tax matters. The team is ranked Band 1 in the Chambers High Net Worth Guide for Tax: Private Client. If you would like to discuss any of the matters raised in this episode, or find out more about our work for high net worth clients, 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.

Notice from RBC Brewin Dolphin:

• RBC does not offer tax advice and this does not constitute tax or legal advice. Tax treatment depends on the individual circumstances of each client and may be subject to change in the future.
• The value of investments, and any income from them, can fall and you may get back less than you invested
• Information is provided only as an example and is not a recommendation to pursue a particular strategy.

Hosted on Acast. See acast.com/privacy for more information.