Development Securities Plc & Others v HMRC [2019] UKUT 0169 (TCC)
Julian Hickey led by Sam Grodzinski QC (instructed by Levy & Levy) represented the Appellants on appeal from the First-tier Tax Tribunal concerning whether certain companies were resident outside the United Kingdom for corporation tax purposes. The appeal was allowed by Mr Justice Marcus Smith and Judge Guy Brannan, who held that the Appellants were non-UK tax resident (and were not dual tax resident). The case deals with important issues concerning the application of central management and control principles (De Beers / Wood v Holden) to tax planning arrangements. Judgement is available here.
