THE COMMISSIONERS FOR HIS MAJESTY鈥橲 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 鈥� statutory residence test 鈥� taxpayer exceeding 45 days in the UK 鈥� 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 鈥� HMRC鈥檚 appeal allowed
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Published 28 July 2023