An IR20 sunset

I wrote about the case of Shepherd [2005] STC (SCD) 644 just over a year ago (Wise guidance?).

Captain Shepherd claimed that he had left the UK and set up a new home in Cyprus but he actually spent less time in Cyprus than in the UK. Whilst the matter was not entirely free from doubt it appeared that on the basis set out in HMRC's booklet on residence IR20 of ignoring the day of arrival and day of departure for any visit Captain Shepherd was in the UK for less than 90 days a year on average during 1998-99 and 1999-2000.

However including the day of arrival and day of departure he was flying for about 180 days a year on average (he was employed by British Airways as a long-haul pilot). Because he often arrived in the UK the day before...