In S Gulliver v HMRC [2017] UKFTT 222 (13 March 2017) the FTT found that HMRC could open an enquiry into the domicile of a taxpayer even though it had accepted in an earlier tax year that the taxpayer was no longer UK domiciled.
HMRC had launched an enquiry into Mr Gulliver’s return in order to establish whether he was domiciled in the UK. Mr Gulliver was born in the UK but had spent ‘significant amounts of time’ living in the Far East. This was an application for a closure notice.
Mr Gulliver argued that HMRC had already accepted that he was not domiciled in the UK in previous correspondence relating to an alleged transfer of value for IHT purposes. At the time Mr Gulliver had argued that he was not domiciled and HMRC had accepted that no transfer of value had taken place without commenting on...
