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The taxpayer was born in the UK. She moved to Spain in 2000 largely for health reasons; her partner remained in the UK.
She returned in 2008 to live permanently in the UK to which she had made several lengthy trips while living overseas.
The taxpayer made disposals of substantial amounts of shares in 2003/04 2004/05 and 2006/07 in respect of which HMRC raised capital gains tax assessments.
She appealed claiming she was resident in Spain not the UK for the relevant years.
The First-tier Tribunal accepted the appellant’s health had motivated her move to continental Europe and that she hoped her partner would eventually join her. It was agreed she had spent 72 days in the UK in 2003/04 83 days in 2004/05 and 108 in 2006/07.
However – with reference to R (on the application of Davies and another)...
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