Protect your clients from costly compliance errors by mastering the hidden nuances and most overlooked pitfalls of the UK Statutory Residence Test.
UK tax residence sits at the heart of cross-border tax planning and remains one of the most heavily scrutinised areas by HMRC. While the Statutory Residence Test (SRT) provides a structured framework, determining a defensible residence position goes far beyond day counting.
This practical course breaks down how to apply the SRT in real-world scenarios involving internationally mobile individuals, executives, founders, and private clients. It explores how residence is shaped by homes, family links, work patterns, travel behaviour, and treaty considerations, and how to properly evidence those conclusions.
Participants will also examine dual residence risks, Article 4 treaty tie-breakers, split-year treatment, and how residence analysis now interacts with the post-2025 UK regime—including the 4-year FIG rules, Overseas Workday Relief, and the evolving long-term residence framework for inheritance tax. The focus is on building robust, audit-ready positions that can withstand HMRC scrutiny.
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Owner and CEO | Vectigalis TAX
Mr Angelo Chirulli is a senior International Tax, Corporate Tax, and Personal Tax adviser with over 25 years of experience advising individuals, businesses, and multinational groups on complex cross-border tax matters. He specialises in international structuring, transfer pricing, corporate reorganisations, tax residence and domicile issues, and HMRC disclosures. He provides strategic advisory support across areas such as international expansion, permanent establishment risk, treaty access, group restructuring, wealth planning, inheritance tax, and global compliance frameworks. His work focuses on technically complex and high-stakes tax scenarios where multi-jurisdictional rules intersect. Angelo also supports clients with transfer pricing documentation (including OECD-compliant Master Files and Local Files), cross-border reporting obligations, and risk mitigation strategies for multinational operations. Alongside advisory work, he is involved in professional training and lecturing in international tax, contributing to practitioner education in advanced tax topics.
