Remittances from joint account

The taxpayer a Swiss national was employed in the UK from April 2006 to October 2008 during which time he claimed he was resident but not ordinarily resident in the country.

In his tax return for 2006/07 he showed total earnings of £304 761 of which £147 936 related to earnings from the UK and was taxable under ITEPA 2003 s 25 with the balance being overseas income not remitted to the UK and therefore not taxable.

For 2007/08 his total income was £674 127. He reported that £490 621 related to his UK earnings. The rest was in respect of non-UK workdays and had been paid offshore and not remitted to the UK.

The taxpayer's salary was paid into a bank account in Guernsey. Some of the money was used in the UK and some was transferred to a joint...