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John Hargreaves v CRC, Upper Tribunal (Tax and Chancery Chamber)
The taxpayer was the largest shareholder in the retail group Matalan.
He sold a large tranche of his shares in May 2000 having moved to Monaco two months earlier in an effort to escape a capital gains tax (CGT) liability on the disposal which earned him £200m.
He completed the non-residence pages of his 2000/01 tax return by stating he intended to live outside the UK permanently.
HMRC issued a notice in January 2007 assessing the taxpayer to CGT on the disposal of his Matalan shares. They also issued a notice of determination of ordinary residence for 2000/01 and 2001/02.
The taxpayer appealed but the action was delayed because he also applied for judicial review to quash the residence notification on the ground the Revenue had failed to apply the terms of its IR20 booklet.
He discontinued his judicial review claim when the Supreme Court ruled...
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