Henderson & ors v HMRC [2017] WTLR 949
Autumn 2017 #169The appellants were the four children of Nicholas Henderson. They appealed under s42 of the Income Tax (Earnings and Pensions Act) 2003 and s207 of the Income and Corporation Taxes Act 1988, against HMRC determinations that they had all been domiciled in the UK since their birth. Strictly this appeal only related to tax years prior to 2008-2009, as a new statutory regime governs appeals relating to questions of domicile thereafter.
The parties were agreed that the appeals could be determined by reference to three questions:
- (1) Had Ian Hende...