KEVIN MCCABE v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00280 (TCC)
Upper Tribunal Tax and Chancery decision of MRS JUSTICE BACON and JUDGE VIMAL TILAKAPALA on 12 September 2024
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Residence – whether Appellant had ceased to be UK resident – application of case law test and application of UK/Belgium DTC – held – Appellant remained UK resident – application of COVI limb of DTC tie-breaker resulting in Appellant being deemed to be UK and not Belgian resident – First-tier Tribunal decision upheld – appeal dismissed