Administrative cooperation, Administrative obligations, Common Reporting Standard, Exchange of Information, FATCA, Germany, India, International Tax Law, Law enforcement, Mandatory disclosure, Personal income tax, Residence, Tax Treaties, United Kingdom, United States
When is information on foreign income relevant to a tax investigation?
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on the basis that he was resident, but not domiciled in the UK. On that basis, he was entitled to the remittance basis of taxation….