UK residency: No Gaines for taxpayer in Supreme Court ruling

After a thirteen-year long residency dispute between Seychelles-based British millionaire Robert Gaines-Cooper and HMRC, the Supreme Court has found in favour of the taxman. The case concerned the interpretation of HMRC's now defunct IR20 guidance on when an individual becomes non-resident and not ordinarily resident in the UK. Gaines-Cooper, who migrated to the Seychelles in 1976, argued IR20 contained a more benevolent interpretation of those circumstances than was reflected in the ordinary law, and, as such, a legitimate expectation arose that this interpretation would be applied b...