Taxpayer was domiciled in England

The taxpayer’s father came to England in 1938 from Austria to escape Nazi persecution. The taxpayer’s mother was born in Ireland but had lived in England since 1953. The taxpayer was born in England and lived here all his life. A dispute arose as the taxpayer’s domicile. He claimed in essence that he had never decided to make the UK his home – he was a ‘global person’ and could settle in other countries in particular the US or Israel. HMRC said he was domiciled in the UK.

This was a lengthy decision that involved the First-tier Tribunal examining the domiciles of the taxpayer’s parents as well his own. It concluded that his father having fled to the UK never wished to return to Austria and indeed maintained an anti-Austria stance for the rest of his life. He served in the British forces during World...