Monaco attraction

Whether taxpayers had made a distinct break in their UK residence

The taxpayers were British and lived in the UK until 2006 when they decided to move to Monaco. They bought a house there but kept their UK property for use as a holiday home when they visited. They gave up their NHS medical cards removed themselves from their GP practice surrendered their UK driving licences and sold their investments. They registered with a doctor dentist and cardiologist in Monaco. They also have Monaco bank accounts and credit cards but kept their UK ones. They ensured their visits to the UK were under 90 days each tax year.

They continued to be taxable in the UK because they had various sources of UK income and they remained as directors of their group of companies. HMRC issued assessments for the years 2006-07 to 2008-09 and 2010-11 to...