A Mackay v HMRC

Cathya Djanogly

In A Mackay v HMRC [2018] UKUT 378 (22 November 2018) the UT found that the taxpayer had been ordinarily resident for the purpose of ITEPA 2003 s 26.

Mr Mackay was born and brought up in Australia. He married in the UK and lived there for five years. He then decided that his wife and two children should continue living in the UK but that he would pursue his career in Asia. He eventually returned to the UK ten years later in December 2004. His first role in London which he held until June 2005 only involved spending 15% to 20% of his working days abroad. However his second role from July 2005 to October 2007 involved 30% to 40% of travelling time abroad. Mr Mackay contended that in January 2005 his expectation had been that he would not be based in the...

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