Derek William Hankinson v HMRC

[2009] UKFTT 384 (TC)

30th October 2009

First Tier Tribunal (Tax)


The issues were, in terms of £30m plus of income and capital gains tax, the appellants’ residence during 19997/98 and 1998/99 and the validity of the “discovery” assessment. The primary dispute was whether the appellant worked “full time” abroad and the application of the practice published by HMRC in the booklet IR 20 “Residence and non-residence: UK liability to tax”-paragraphs 2.2 et seq. There was also an issue in terms of the Anglo Belgian double tax treaty and dual residence. The appeal dismissed and the assessment upheld as valid.

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