In J Charman v HMRC [2018] UKFTT 765 (20 December 2018) the FTT found that a founder’s fee of $2.5m paid to the taxpayer in February 2013 was subject to UK tax on the basis that he was still resident in the UK at that date even though he had taken steps to leave.
Mr Charman was employed in the UK until 2001. By that date he was a very senior executive in the insurance industry. He believed that his marriage was over when he accepted a role with Axis Specialty a company established in Bermuda in October 2001. He had a regular pattern of travel during the relevant years of leaving the UK on a Monday afternoon flight for Bermuda and returning to the UK on a Friday morning on an overnight flight from Bermuda. He retained his personal effects (documents clothing...
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