P is an architect who designs hospitals and clinics located in various African and Indian states. He left the UK in 2009/10 because his wife’s employment requires her to live abroad.
He expects to return to live in the UK in 2016/17. He owns a house in the UK which is available to him but he has visited the UK for fewer than 90 days per tax year since he left in 2009/10.
P is convinced he is not resident in the UK for tax purposes from the point he left in 2009/10 and we are inclined to agree.
P is a director of M Ltd a UK-registered trading company and also owns 50% of its shares. R holds the other 50% of M Ltd but R is not related to P.
P invoices M Ltd for the work he does as a self-employed architectural consultant...
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