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The appellant was born in the UK. He became the managing director of a UK company B in 1982.
In 1985 he arranged a management buy-out and in 1987 he transferred his shares to non-UK resident family trusts.
He remained a director of B and became its chairman in 1992. In 1997 the trusts sold their holdings in B to a venture capital fund realising substantial capital gains but retained an interest in B.
In February 1998 the appellant began working for M a Netherlands subsidiary of B while still chairman of the latter. The capital gains realised by the trusts crystallised In March 1999.
In his 1998/99 tax return the appellant stated he had not been resident or ordinarily resident in the UK and that he had been working in the Netherlands during that year.
In...
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