Taxpayer was settled and domiciled in England

The taxpayer was born in 1949 in the UK to parents who had arrived in the UK in 1938 from Europe. Other than for a short period between 1967 and 1970 the taxpayer has lived in Manchester where he has a property business and established a Jewish community. He prepared his tax returns on the basis that he was not domiciled in England but had a domicile of choice in Israel which he had acquired while staying there for a few months in 1970. He argued that having a home or being settled in a place did not satisfy the test for a domicile of choice. It had to be accompanied with the intention to remain resident for an indefinite period. Further he had bought burial plots in Israel for himself and his wife.

HMRC considered that the taxpayer was domiciled in England given that his father had chosen...