The English Appeal Court has rejected claims that an international businessman, had qualified for exemption from
UK taxes as a non - resident.
The Appeal Court stated that " England had remained to be the businessman's chief residence". The businessman has been domiciled in a villa in the Seychelles for more than 30 years and spent no more than 90 days in the UK.
The Appeal Court said the businessman had failed to show " a distinct break " from his social and family ties in the UK and his complaints of unfair treatment were based on an " impossible construction " of the law.
The Appeal Court further stated that " the 91 day rule could not establish non - domicile status , but was important to establish whether non - resident staus, once acquired, has been lost".
The Court of Appeal ruled that the Revenue were " fully entitled to look for a clear break - or a clean break - with this country before affording non - resident status.
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