The Non-resident Landlords Scheme (NRL Scheme) requires income tax at the basic rate to be deducted from rental payments due to non-resident landlords in respect of a UK property business and accounted for to HMRC. The NRL Scheme must typically be operated by: • letting agents (regardless of the amount of rent involved), or • if the landlord does not have a letting agent, tenants (paying rent of more than £100 per week (or £5,200 per year) or where there is occupation for less than one year a proportionate sum determined by reference to the duration of their occupation or who is notified by HMRC that they should operate the NRL Scheme) HMRC publishes detailed guidance notes for letting agents and tenants in relation to the operation of, and their obligations under, the NRL Scheme (referred to collectively herein as the ‘Guidance Notes’). In calculating the tax, the letting agent or (in limited circumstances) the tenant may deduct certain expenses. These deductible expenses are similar to (but more limited than) the allowable expenses

Requires income tax at the basic rate to be deducted from rental payments due to non-resident landlords in respect of a UK property business and accounted for to HMRC.

The Practice Note deals with the income tax and capital gains tax (CGT) issues arising for individuals who were not UK resident and not domiciled in the UK (ie neither actually domiciled nor deemed domiciled in the UK) before 6 April 2025. Note that where the individual is not resident in the UK, the rules set out below for income tax and CGT will generally apply irrespective of the individual’s domicile status. Residence is not generally a relevant concept for inheritance tax (IHT) purposes; instead the relevant concept is domicile. However, the residence status of the individual will be relevant in carrying out IHT planning because potential charges to income tax and CGT will need to be taken into account. For a summary of the UK tax issues for non-resident individuals, see Practice Note: Introductory guide to UK tax for non-resident individuals. Abolition of non-dom regime and introduction of residence-based IHT regime Finance Act 2025 (FA 2025) which received Royal Assent

A term used in relation to both private children proceedings and regarding statutory child support in relation to the parent with whom a child does not primarily live.

Stop Press: Finance Act 2026 (FA 2026) makes two changes to the non-resident capital gains tax rules. (1) FA 2026, s 40 provides that, for the purpose of TCGA 1992, Sch 1AA (ie whether an asset derives at least 75% of its value from UK land and whether a person making a disposal of that asset has a substantial indirect interest in UK land) each cell of a protected cell company (PCC) is treated as if it were an individual company. This change has effect in respect of disposals made on and after 26 November 2025. (2) FA 2026, s 41 provides that where (i) a company or individual disposes of an asset that derives at least 75% of its value from UK land, (ii) the disposal has an ‘appropriate connection’ to a collective investment vehicle (CIV) (within the meaning in TCGA 1992, Sch 5AAA, para 6), and (iii) the gain is exempt from tax under a double taxation treaty, then the company or individual is

The usual procedure for divorce or dissolution where the simplified procedure is not adopted, and the proceedings under the non-simplified procedure may be undefended or defended.

Affiliate • means any entity that directly or indirectly controls, is controlled by or is under common control with, another entity; Relevant Period • means the Term of the Agreement; Restricted Period • means the Term of the Agreement [and a period of [insert period, eg six months] after its completion, expiry or termination]; Restricted Person • means [any person employed or engaged by either party at any time during the Relevant Period in a [enter details of relevant roles eg senior sales, marketing, or operational roles]

When deciding whether a post-termination non-solicitation clause in an employment contract has been breached, (1) the question of whether the client of the former employer or the ex-employee was the first to initiate contact is relevant but not decisive and, where it was the client, that fact does not exclude the possibility that solicitation occurred, and (2) for there to have been solicitation, the ex-employee must, directly or indirectly, have conveyed a message which requested, or sought to encourage or persuade, the client to transfer his custom, according to the High Court in Towry EJ v Bennett, Raymond James Investment Services and others.

This Practice Note sets out Employment Appeal Tribunal (EAT) procedure in a number of non-standard and less frequently-arising situations. These are where the EAT makes a reference back to the employment tribunal for clarification under what is known as the Burns/Barke procedure, where the appeal relies on the alleged inadequacy of the tribunal’s written reasons, where the grounds for appeal include allegations of bias or improper conduct by the tribunal or procedural irregularities at the tribunal hearing, appeals which cannot be argued without reference to evidence given or not given at the tribunal, appeals relying on new evidence and those or arguing a new point of law. It also sets out the EAT’s power to make a restricted reporting order in any case involving allegations of sexual misconduct and disability, and discusses appeals involving allegations of the commission of a sexual offence. Finally, appeals involving state immunity are addressed and the modified EAT rules which apply in the case of any appeal involving national security proceedings. Appeals relying on inadequacy of employment tribunal's reasons In

This Practice Note examines the non-statutory bars to extradition, including abuse of process, human rights issues and the arguments relating to time served. For information relating to the statutory bars to extradition, see Practice Note: Statutory bars to extradition. For further reading on the extradition procedure which applies under the Extradition Act 2003 (EA 2003), see Practice Notes: Extradition—arrest and initial procedure and Extradition hearings. Abuse of process The court has jurisdiction to consider whether extradition is barred by reason of abuse of the court’s processes. This bar to extradition is not found in EA 2003, but rather has been established by caselaw. The abuse of process argument is a free standing ground which should be considered after any statutory bars or human rights issues. The presumption is that the requesting state has acted in good faith and the individual whose extradition is sought must therefore satisfy the extradition judge that this is not the case. In Belbin v France, the High Court made the following statement: ‘We wish to emphasise that the

Tax analysis: In Airline Placement, the High Court dismissed the taxpayer’s application for judicial review. The taxpayer’s 2009 request for NSC about the VAT treatment of the arrangements, and the documents accompanying such NSC request, were materially inaccurate and misleading and did not provide full and frank disclosure of the arrangements, so the taxpayer had no legitimate expectation that the VAT treatment detailed in the NSC would not be revoked by HMRC. The High Court therefore did not quash HMRC’s 2021 decision about the VAT treatment of training bonds (which differed from the VAT treatment outlined in the NSC) and also did not quash the consequential VAT assessment issued by HMRC.

The Advance Tax Certainty Service for qualifying major investment projects is a separate statutory clearance regime and does not form part of the non-statutory clearance procedure. For an overview of its eligibility, scope, process and binding effect, see Practice Note: Statutory clearances. This Practice Note sets out: • when it is appropriate to submit a non-statutory clearance (NSC) application within annex A to HMRC's guidance • the purpose of NSC applications • what a NSC application should not cover • the content required by HMRC to be included in a NSC application • when a clearance received from HMRC under the NSC procedure can be relied on, and • practical considerations where HMRC's view and the taxpayer's view of the application of tax law to a transaction differ The NSC procedure is the replacement for the non-statutory business clearance (NBC) and Clearances and Approvals 1 (CAP 1) procedure. For a Precedent NSC letter, see: Clearance letter—non-statutory clearance. For a guide explaining the NSC application process in simple practical steps, see Practice Note: How to apply for a non-statutory