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The Right Honourable Clifton Hugh Lancelot de Verdon Baron Wrottesley (TC4084)
The taxpayer was born in Dublin, educated in the UK, and married to a Swiss woman with whom he lived in Switzerland and London.
HMRC opened an enquiry in 2001 into his claim that he had abandoned his UK domicile of choice.
The department rejected the claim and issued determinations for 2000/01 to 2007/08 on the basis the taxpayer was domiciled in England and Wales during those years. He appealed and applied to the First-tier Tribunal for a preliminary hearing to determine his domicile of origin.
The tribunal judge concluded that the taxpayer’s domicile of origin could not be “entirely divorced from the substantive issue: his domicile between 2000/01 to 2007/08”. A preliminary hearing on the issue would not settle the matter, and it would be preferable to have one hearing to determine all points under appeal.
The taxpayer’s application was dismissed.
