INCOME TAX – preliminary issues – domicile, residence and ordinary residence in tax years 1992/93 to 2003/2004 – Appellant purchased house in the Seychelles in 1975 and obtained a residency permit in 1976 – Appellant indirectly retained house and assets in England – latterly the Appellant’s wife and son resided in England – whether the Appellant retained his domicile of origin in England – yes – or whether Appellant acquired a domicile of choice in the Seychelles – no – whether the Appellant was resident in the United Kingdom – yes – whether the Appellant was ordinarily resident in the United Kingdom – yes – appeal on the preliminary issues dismissed – ICTA 1988 s 336

Michael Flesch QC and Nicola Shaw appeared for the Appellant