In Darrell Healey v HMRC [2014] UKFTT 889 – 11 September 2014 the FTT dismissed an application for a preliminary hearing to decide whether a 12 months’ absence from the UK constituted a distinct break.
On 2 April 2006 Mr Healey had left the UK and taken residence in Monaco. In the tax year 2007/08 he did not set foot in the UK and HMRC accepted his contention that he was working abroad and that he was therefore not resident in the UK.
In the tax year 2008/09 Mr Healey undertook substantive duties in the UK on 71 days and HMRC considered that he had again become resident in the UK.
Mr Healey contended that he had effected a ‘distinct break’ when leaving the UK in April 2006 and that therefore he should be taxed as an ‘arriver’ in the UK for the tax year 2008/09....
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