HMRC are consulting widely on issues relating to residence, with a view to publishing revised guidance in the new year. It had been suggested that a new IR20 would be issued by the end of this year, but this possibility has now been overtaken by new proposals, and it seems that IR20 will be completely replaced. It is hoped that the various Applications for Judicial Review in the pipeline on different aspects of IR20 will have been heard by then – and they will be able to provide some welcome clarity to the whole subject. The most important thing is that we have guidance on which we can rely.
I will have more to say on this subject next month following the Application for Judicial Review in the case of Robert Gaines-Cooper, which has now been heard.