THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS v A TAXPAYER [2023] UKUT 00182 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Michael Green and Deputy Upper Tribunal Judge Anne Redston on 28 July 2023
INCOME TAX – statutory residence test – taxpayer exceeding 45 days in the UK – whether taxpayer would not have been present at the end of each extra day but for exceptional circumstances beyond her control which prevented her from leaving the UK – HMRC’s appeal allowed
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Published 28 July 2023