Taxpayer did not cease to be resident in the UK

The taxpayer was the founder and chief executive of a successful UK property group. 

He moved to Brussels on 4 April 2006 partly to develop and grow the group’s European business and partly for tax reasons to ensure that he was non-resident when he sold shares in the property group. 

Although he lived in Belgium for seven years (acquiring business and residential property there) and he paid substantial amounts of tax to the Belgian authorities the First-tier Tribunal (FTT) had concluded taking all of the evidence into account that he had not sufficiently loosened his ties with the UK and that therefore he remained UK-resident throughout.