A crackdown on wealthy tax exiles could be on the cards after a landmark victory for HMRC at the Court of Appeal yesterday over its interpretation of residency laws.
The court decided that HMRC had used the correct interpretation of the UK’s non-resident policy, IR20, meaning that British-born entrepreneur Robert Gaines-Cooper is liable to pay UK tax, despite spending less than 91 days a year in the country. He may now have to pay taxes dating back to 1993, the total of which is estimated at some £30m.
Gaines-Cooper had appealed on the basis that he moved to Seychelles in 1976, but it was ruled that he never qualified for exemption from British taxes as a non-resident since he had not cut ties with the UK.
The businessman owns an estate in Oxford, where his second wife an...