For the latest New Development, see ND.2620.
For a discussion of the concept of domicile, see E6.300A. For commentary on domicile enquiries, see E6.310.
In Al Fayed1 it was held that an agreement by a non-domiciled individual to pay lump sums in satisfaction of liability to all UK taxes for a number of tax years was outwith HMRC's powers (ultra vires). HMRC had no discretion to continue to
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