Stephen Norman Rumbelow v HMRC

In Stephen Norman Rumbelow v HMRC (TC03022 – 31 October) Mr and Mrs Rumbelow contended to have ceased being UK resident on 4 April 2001.

Following the Supreme Court’s decision in Gaines-Cooper ([2011] UKSC 47 the tribunal had to decide whether a ‘distinct break’ in the pattern of their lives had taken place relying on a multifactorial enquiry. It was established that Mr Rumbelow had wanted to retire from his property business and that the Rumbelow’s had hoped that the slower pace and better weather of Portugal would suit them. However following changes in Portugal tax law they had been advised to take up residency in Belgium first. On 4 April 2001 in what seemed a rather precipitated move governed by a desire to have become non-resident by the start of the year 2001/02 they had left the UK in a...