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Glyn v CRC, Upper Tribunal (Tax and Chancery Chamber), 12 October 2015
In 2005 the taxpayer a British citizen decided to emigrate with his wife from the UK to Monaco indefinitely.
In 2005/06 he had received a large dividend from his main UK company the tax on which would have been about £5.5m had he remained resident in the UK. He also wished to stop working and change his lifestyle. He was married with three grown-up children and owned a property in London which he kept while living in Monaco.
The taxpayer said he had a new way of life. He believed that he could make a limited number of visits to the UK and that retaining his UK home would not affect his claim to be non-UK resident. In 2010 he and his wife returned to the UK permanently and moved back...
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