KEVIN MCCABE v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2024] UKUT 00280 (TCC)
Upper Tribunal Tax and Chancery decision of MRS JUSTICE BACON and JUDGE VIMAL TILAKAPALA on 12 September 2024
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Residence 鈥� whether Appellant had ceased to be UK resident 鈥� application of case law test and application of UK/Belgium DTC 鈥� held 鈥� Appellant remained UK resident 鈥� application of COVI limb of DTC tie-breaker resulting in Appellant being deemed to be UK and not Belgian resident 鈥� First-tier Tribunal decision upheld 鈥� appeal dismissed