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The taxpayer worked for a non-UK company in Norway and was also a qualified merchant navy seafarer. He was paid from abroad and the money was remitted into a UK bank account.
No deductions were made to his pay because he worked full-time outside the UK. The taxpayer’s agent HTSL claimed he was non-UK resident for the period from August 2003 to September 2005.
HMRC disputed the method used for counting days in the UK and refused the claim. The taxpayer appealed.
HTSL said it had complied with the HMRC’s south Wales working practice which had been used for about 30 years in calculating the taxpayer’s claim.
Furthermore that tax office was agreeing other taxpayers claims which were exactly the same as the taxpayer’s. It was not fair that because the taxpayer’s tax office was Centre 1 he should be treated differently.
HMRC claimed the...
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