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FTT cases on residence: lessons from Glyn and Rumbelow

Following HMRC’s long line of victories in tax residence cases over the last few years HMRC has now lost a case at the First-tier Tribunal. The case James Glyn (TC03029) published on 17 November concerns a taxpayer who following tax advice left the UK to become non-UK resident and subsequently received a sizeable dividend of £29m.

HMRC contended that Mr Glyn remained UK resident during the period so that the dividend was subject to UK tax. Their main arguments were that: Mr Glyn had not shown a ‘distinct break’ from the UK because he had not shown a sufficient loosening of his family and social ties; and Mr Glyn’s visits to the UK were for a ‘settled purpose’.

These arguments centred on the fact that Mr Glyn retained a six bedroomed family home in North London. He frequently returned there to observe Friday night family...

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