An application by the appellant for his domicile of origin to be determined as a preliminary issue in advance of his main appeal against an HMRC determination of his domicile status was refused.
In April 2001, the appellant filed a claim with the Inland Revenue that he was not domiciled in the UK as from around the year 2000. In providing details of the claim, the appellant maintained that his domicile of origin was Irish. Following an enquiry, in April 2012 HM Revenue and Customs issued notices of determination that the appellant was domiciled in England and Wales during the tax years 2000/01 to 2001/02 inclusive. The appellant appealed.
Both parties agreed that the appellant’s domicile of origin would need to be determined in order to decide his domicile during the tax years in question. However, the appellant claimed that his domicile of origin was a discrete issue for which the limited relevant evidence had already been
