Thanks Sparkle. That does make some sort of sense but still seems a little unfair and presumably Federer will have the same problem, although he ditched Queens in favour of Halle in 2010 claiming that he preferred it anyway especially as it has a roof and is also close to home.
Like I said, I think the rule has been changed now, which I think is right, but I won't shed tears because the super-rich have to pay a little (to them) bit of extra tax.
It makes perfect sense for Federer to play Halle in terms of location. Rumour had it that he was in the huff with Queens, because they wouldn't give him such a big appearance fee. It's not as if Queens struggles to sell tickets, so it's all a bit academic.
Not that our guesses about probably outdated UK tax law have much to do with Andy in Valencia, so perhaps we should save that for another thread.