Tax exiles under threat following Court ruling

clock •

Thousands of tax exiles could face hefty bills after the Court of Appeal upheld the right of HM Revenue and Customs to retrogressively tax a businessman who has lived in the Seychelles since 1976.

The court ruled that despite abiding by the rules to spend less than 91 days per tax year in the UK, Robert Gaines-Cooper had not ‘cut his ties' with the country and was therefore still liable to pay tax. Gaines-Cooper may now have to pay a tax bill of £30m, for the years from 1993 to 2004. The crux of the Revenue's old guidance on whether someone was resident in the UK for tax purposes - known as IR20 - was whether they spent, on average, fewer than 91 days in the country each year. However, the Appeal Court judges ruled it had always been the case that any would-be tax exile firs...

To continue reading this article...

Join Professional Adviser for free

  • Unlimited access to real-time news, industry insights and market intelligence
  • Stay ahead of the curve with spotlights on emerging trends and technologies
  • Receive breaking news stories straight to your inbox in the daily newsletters
  • Make smart business decisions with the latest developments in regulation, investing retirement and protection
  • Members-only access to the editor’s weekly Friday commentary
  • Be the first to hear about our events and awards programmes

Join

 

Already a Professional Adviser member?

Login

More on Investment

Budget 26: Stamp Duty on shares to be swapped for Securities Transfer Tax

Budget 26: Stamp Duty on shares to be swapped for Securities Transfer Tax

By late 2027

Patrick Brusnahan
clock 28 October 2026 • 1 min read
Investment tax relief rises by smallest amount in four years amid recent Budget measures

Investment tax relief rises by smallest amount in four years amid recent Budget measures

Bowmore Financial Planning research

Jack Roach
clock 28 October 2026 • 2 min read
Defaqto to launch rating for newer funds and portfolios

Defaqto to launch rating for newer funds and portfolios

Combines Defaqto and RSMR expertise

Jen Frost
clock 27 October 2026 • 2 min read