The taxpayer did not sufficiently loosen his ties to the UK prior to 6 April 2012 such that he was not UK resident, thereafter, so he was chargeable to capital gains tax on disposals made in the tax year 2012/13.  

Summary 

The taxpayer did not sufficiently loosen his ties to the UK prior to 6 April 2012 such that he was not UK resident, thereafter, so he was chargeable to capital gains tax (CGT) on disposals made in the tax year 2012/13. 

Background 

The appellant was assessed by HM Revenue and Customs (HMRC) to CGT on the sale of various UK properties during the tax year 2012/13 on the basis that he was resident in the UK. HMRC considered that the appellant was UK resident for at least one day in the tax year 2012/13, whereas the appellant maintained that he had ceased to be UK tax resident prior to 6 April 2012 and any presence in the UK thereafter fell within the