- FTT considers individual’s treaty residence (Oppenheimer v HMRC)
- Why it matters
- Case details
Tax analysis: In Oppenheimer v HMRC, the First-tier Tax Tribunal (FTT) considered the UK-Republic of South Africa (RSA) double taxation treaty (DTT), and determined on the facts that an RSA national’s personal and economic relations (centre of vital interests) were closer to the RSA than the UK and on that basis upheld his appeal against assessment. In case it was wrong on that issue, the FTT also considered the question of habitual abode (which it considered to be more difficult), and also found that to be in the RSA.
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