The First-tier Tribunal directed that the appellant’s appeal against tax assessments be stayed until 28 days after the determination of his appeal against information notices relating to the same tax years. 

In February 2020, HM Revenue and Customs (HMRC) issued information notices (under FA 2008, Sch 36) to the appellant for seven of the eight years 2011/12 to 2018/19 (the exception being 2014/15) relating to his domicile and worldwide income. The appellant appealed against the notices on the grounds that the information was not ‘reasonably required’ because he was not domiciled in the UK (the ‘notices appeal’), and that his domicile should be decided as part of the notices appeal. 

The appellant’s barrister had put forward essentially identical submissions in another case (regarding a Mr Robert Perlman). A preliminary hearing of Mr Perlman’s case took place in April and May 2021 (Perlman v HMRC ]