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 day ...
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