Tax Tribunal Rules Peripatetic Businessman 'Ordinarily Resident' in the UK
26th February, 2021Many businesspeople lead peripatetic lives of constant international travel and the crucial question of whether they are settled in the UK for tax purposes can be very difficult to answer. A First-tier Tribunal (FTT) ruling, however, revealed the lengths to which HM Revenue and Customs (HMRC) will go to establish that a taxpayer is ordinarily resident in this country. The case concerned the tax treatment of £578,400 received by an overseas national on the severance of an employment contract. He claimed that, by virtue of Section 414 of the Income...