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HMRC v A Taxpayer

Upper Tribunal takes robust view of exceptional circumstances for statutory residence test.

In HMRC v A Taxpayer [2023] UKUT 182 (TCC) (28 July 2023) the Upper Tribunal (UT) overturned the decision of the First-tier Tribunal (FTT) allowing HMRC’s appeal. It held that the taxpayer had not been prevented from leaving the UK and the...

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