E6.124O Split year treatment pre 6 April 2013—overview
In the absence of any statutory definitions of 'residence' and 'ordinary residence', HMRC evolved an administrative code of practice based on statute and case law, which applied up to 5 April 2013. This code of practice was for many years set out Booklet IR20, together with statements of practice and published extra-statutory concessions1.
Although Booklet IR20 stated that 'it was not binding in law'2, and the then Inland Revenue had occasionally demonstrated that it would challenge taxpayers even if they fell within the terms of the guidance3, its chief disadvantage
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