KO Pflum v HMRC

In KO Pflum v HMRC (TC02051 – 19 June) an individual (P) whose main home was in Germany worked in the UK from April 2006 to October 2008 during which time he was accepted as resident but not ordinarily resident in the UK. His fiancée (L) had lived in the UK since 2003 having arrived as a student. P’s earnings for days when he was working in the UK were taxable under ITEPA 2003 s 25 and his earnings for days when he was working outside the UK were chargeable under ITEPA 2003 s 26 (so that they were only taxable if they were remitted to the UK). P’s salary was paid into a Guernsey bank account. In his 2007/08 tax return P stated that he had earned £490 621 relating to duties outside the UK and that only...