The case of Gaines-Cooper v Revenue and Customs Commissioners has raised considerable interest in the press. It concerns a multi-millionaire who found to his cost that HMRC publishes one set of rules on UK temporary residency but argues questions of residency on an entirely different basis in the courts.
Richard Mannion, national tax director of Smith and Williamson, shares his views on the decision as it currently stands.
The case of Gaines-Cooper v Revenue and Customs Commissioners has raised considerable interest in the press.
Probably the main point of interest in this case concerns the Revenues assertion that the guidance in booklet IR20 did not apply in the case of Mr Gaines-Cooper.
Para 1.2 of the booklet says the normal rule is that days of arrival in and departure from the UK a...