Another victory for the Revenue on residence
The Revenue has won the case against music agent Lee Barrett, who was claiming that he was not liable for tax on income received in a year when he was not UK resident.
The Case follows on from the landmark decision on residence in the Gaines-Cooper case, and shows a much stricter approach from the Revenue.
Briefly, Mr Barrett, who was born in Canada but grew up in the UK, argued that he was not resident in the UK during the period when he received the payment, and so not liable to tax.
The Court ruled that the tax was payable, and Mr Barrett could not show that he had made a ‘distinct break’ in his pattern of life and so remained resident in the UK.
