Year or there

Our client is a very wealthy non-domiciled individual with various non-UK business interests which are generating substantial personal income.

For personal reasons he came to live in the UK in January 2006 before the non-domicile tax charge was introduced.

We have since 2009 been declaring our client as UK-resident and claiming remittance basis for his non-UK income but there has been no requirement to pay the £30 000 tax charge because he has been resident here for less than seven out of the previous nine years.

However from January 2013 our client will have been continuously resident in the UK for seven years.

It is unclear whether 2006/07 when our client was only resident for three months of the tax year counts as a year of residence for the non-dom charge or whether 2007/08 is the first year which counts because that...