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The taxpayer appealed against HMRC’s contention that the deceased had a domicile of choice in the UK.
The deceased was born in Karachi when it was part of British India. It was not disputed that his domicile of origin was not the UK. His father was born in Gujarat which was also part of British India.
He lived for periods in Karachi and Tanzania until 1954 when moved to the UK to study at university. In 1957 he moved back to Tanzania. In 1961 when Tanzania gains independence from the UK the deceased was offered and acquired UK citizenship. He had to give up his Indian citizenship because India does not permit dual citizenship.
In 1973 the deceased moved to the UK with his wife and children; his mother followed a year later because her sons were all in the UK.
Between 1973 and 1997 the deceased worked...
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