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Paul Daniel v HMRC

In Paul Daniel v HMRC (TC03312 – 10 February 2014) the first issue was whether Mr Daniel had left the UK and worked full time abroad so as to have become non-UK resident for the relevant tax year.

Having extensively reviewed Mr Daniel’s whereabouts and activities during the relevant tax year the tribunal found against the taxpayer. During the first part of the year Mr Daniel had not worked at all for countless weeks. In relation to the second part of the year during which he had resided mainly at his holiday home in France the tribunal rejected Mr Daniel’s contention that he had worked full time on a specific project (the ‘project’). Finally Mr Daniel’s most ‘crucial contributions’ to the project were made at meetings in London with substantial preparatory work in London.

The tribunal also had to decide whether the taxpayer had...

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