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HMRC v James Glyn

In HMRC v James Glyn [2015] UKUT 551 (12 October 2015) the UT found that the FTT had made errors of law in considering whether Mr Glyn had become non-UK resident.
Mr Glyn had received a £24.5 million dividend payment and the issue was whether he had been UK resident at the time.
Having decided to retire from the property business he had set up with his brother Mr Glyn had superimposed a holding company above his existing company which had sold all its properties. His shares had then been redesigned as carrying a special dividend representing half of the net proceeds of the property sale. Mr Glyn had also decided to become non-resident. He had acquired an apartment in Monaco and taken up residence there. It was accepted that the apartment was furnished as...

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