An application for a closure notice in respect of an HMRC enquiry into the appellant’s domicile status was refused, as HMRC was not bound by its previous confirmation of the taxpayer’s domicile.
The appellant, a UK national with a UK domicile of origin, spent significant amounts of time living in the Far East. In December 2015, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s tax return for 2013/14. The appellant’s domicile status was the only material point outstanding.
In October 2002, the appellant’s advisers had written to HMRC explaining that, in September 2002, the appellant transferred £273,677 (from funds held outside the UK) to a discretionary trust. This sum was above the inheritance tax (IHT) nil rate band, and the contribution would, therefore, have given rise to an IHT liability of some £4,735 if the appellant was UK domiciled at any time in the
