R (on the application of Prudential plc & anr) v Special Commissioner of Income Tax & anr WTLR(w) 2013-03

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R (Davies & anr) v HMRC; R (Gaines-Cooper) v HMRC [2011] UKSC 47

March 2012 #117

The first appellants were property developers who were resident in the UK until 2001 when, with the benefit of professional advice designed to bring about a cessation of their ordinary residence here, they moved to Belgium to take up employment with a Belgian company of which they had become directors and shareholders. They claimed to rely on the general guidance published by the Revenue entitled ‘Residents and non-residents – Liability to tax in the United Kingdom’, known as IR20. Later that year they realised chargeable gains in respect of which they were liable to capital gains tax un...

Radmacher (formerly Granatino) v Granatino WTLR(w) 2010-13

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