Historically the question of residence in the UK has been a difficult one. Very little was defined in legislation, taxpayers had to rely on case law (some in excess of 100 years old) and HMRC guidance, which although issued by the tax authority, did not bind it to accept returns prepared on that basis. Clearly, with an ever more internationally mobile population, this had to change and pressure has been put on successive governments to give certainty to individuals as to their residence status.