The First-tier Tribunal did not have the jurisdiction to decide whether the appellant was UK domiciled as part of a hearing of his appeal against an information notice, but if the tribunal was wrong on that issue and had the jurisdiction, it would not be in the interests of justice for that jurisdiction to be exercised. 

Summary 

The First-tier Tribunal (FTT) did not have the jurisdiction to decide whether the appellant was UK domiciled as part of a hearing of his appeal against an information notice, but if the tribunal was wrong on that issue and had the jurisdiction, it would not be in the interests of justice for that jurisdiction to be exercised. 

Background 

The appellant was born in Curaçao in 1943 and resident in the UK since at least 1967. Following a meeting in September 2017, HM Revenue and Customs (HMRC) concluded