New queries, issue 4312

Cuckoo questions?

My client left the UK permanently in April 2005 and has resided in Switzerland ever since. The inspector dealing with the matter at the time accepted that he therefore became non-resident as from 2005/06 inclusive.

Swiss accountants have been instructed and I understand that tax returns have been completed in that country ever since.

A year or so ago and for reasons not wholly clear to us a new HMRC inspector decided that the case needed further investigation and has raised certain points one of which is rather unusual. He has asked for a schedule from April 2004 to April 2006 showing for each individual day my client’s whereabouts and the names of all the people he was with.

I thought this must be a misunderstanding and pointed out that if required for each...