The Upper Tribunal upheld a First-tier Tribunal decision that bank transfers from an offshore bank account to the UK bank accounts of ‘non-relevant persons’ amounted to a taxable remittance but allowed the taxpayer’s appeal in respect of transactions involving the use of an offshore credit card to make UK purchases.
The appellant, a non-UK domiciled individual, had moved to Dubai in 2007. After a period of non-UK residence, he subsequently became UK resident again from 2014. The appellant held a bank account in Dubai, which was used to make bank transfers and pay off a non-UK credit card that was used to make purchases of goods and services. That bank account contained income from overseas sources. The appellant made a claim to the remittance basis of taxation in his tax return for 
