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The taxpayer claimed he was not resident in the UK and appealed against assessments raised by HMRC on the basis that he was resident for the years 1997/98 to 2002/03.
The appeal before the Special Commissioners went in his favour and HMRC appealed.
The High Court judge concluded the Special Commissioner had made errors of law and that the only possible conclusion was that the taxpayer was resident. He appealed.
The Court of Appeal ruled that the commissioner had misdirected herself but it did not agree with the High Court that the taxpayer was inevitably UK resident.
The case was remitted to the First-tier Tribunal which by then had replaced the Special Commissioners.
The parties agreed on the points at issue before the tribunal but not on whether TA 1988 s 334 was in point.
The effect of the...
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