The UK cases of Shepherd v Revenue & Customs Commissioners 2006 SpC 484 and Grace v Revenue and Customs Commissioners 2007 SpC 663 were brought to the Special Commissioner to conclude on the taxpayer’s residence status. Both cases concerned pilots whose flying base was London airports. Both pilots had previously lived in the UK and both claimed to have ceased to be UK resident.
Availability of split year residence relief on a concessionary basis as per Tax Briefing 17 25TACD2019
This appeal considered tax residency status under the "look back" rule and eligibility for split year residence relief. 08TACD2020
The Respondent in this case was the Criminal Assets Bureau. The Appellant, who was Irish domiciled, but leading a "nomadic" lifestyle was determined not to have been resident in Ireland for certain years and not to have carried on a trade in Ireland during any of those years. 177TACD2020