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The appellant who had been born and educated in South Africa was employed as a long-haul pilot by British Airways.
He had his main residence in the UK until 1997 as his flights began and ended in the UK.
In 1997 the appellant decided to set up home in Cape Town to be near his family and friends and to commute to work.
He bought a house in Cape Town and lived there when he was not working.
He also joined flying clubs and kept private aeroplanes there. He kept a house in the UK which he used for resting between flights.
He also had a car in the UK to enable him to travel to work from his house and had a UK bank account into which his salary was paid.
In 2005 the appellant bought some land in South Africa and once...
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