Caselaw Digest
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Jeremy Coller v The Commissioners for HMRC

[2023] UKFTT 212 (TC)
Jeremy, his dad, and mom lived in England for a very long time and had lots of connections there (houses, jobs, friends). Even though they sometimes talked about moving, their actions showed they were settled in England. So, the tax court said Jeremy had to pay taxes in England.

Key Facts

  • Jeremy Coller appealed closure notices for income tax for the years 2013-2016, based on his domicile in England.
  • The case involved determining the domicile of Jeremy, his father John, and his mother Sylvia.
  • John, born in Austria, fled to England in 1938 and acquired British citizenship.
  • Sylvia, born in Ireland, moved to England in 1954 and married John.
  • Jeremy was born and raised in England.
  • The appeal hinged on whether John and Sylvia acquired a domicile of choice in England, impacting Jeremy's domicile of origin or dependency.

Legal Principles

Domicile of origin and dependence

Udny v Udny, In Patten's Goods, Re, Gulbenkian v Gulbenkian, Potinger v Wightman, Domicile and Matrimonial Proceedings Act 1973

Tenacity of domicile of origin

Dicey, Kelly v Pyres, Barlow Clowes International v Henwood

Domicile of choice

Re Fuld, Dicey, Udny v Udny, Inland Revenue Commissioners v Bullock, Re Fuld, Barlow Clowes International v Henwood

Length of time

Musa, Udny v Udny, Ramsay v Liverpool Royal Infirmary

Intention

Ramsay v Liverpool Royal Infirmary, Re Fuld

Burden of proof

Re Fuld, Winans v Attorney General

Standard of proof

Re Fuld, Barlow Clowes International v Henwood

Evidence

Kelly v Pyres, Cyganik v Agulian, Barlow Clowes International v Henwood, Dicey, Ray v Sekhri, Barlow Clowes International v Henwood, Agulian, Sekhri, Frederick Henderson

Inferences

Barlow Clowes International v Henwood

Perspective

Cyganik v Agulian

Outcomes

Appeal dismissed

The Tribunal found that John and Sylvia had acquired domiciles of choice in England by the relevant dates. This determined Jeremy's domicile as well, even though the Tribunal also considered his case separately.

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