{
"case_information": {
"court": "FIRST-TIER TRIBUNAL TAX CHAMBER",
"case_number": "TC 10016 (Appeal reference TC/2024/03314)",
"citation": "[2026] UKFTT 01319 (TC)",
"applicant": "Sir John Griffin",
"respondent": "The Commissioners for His Majesty's Revenue and Customs",
"jurisdiction": "United Kingdom",
"judgment_date": "15 September 2026"
},
"excerpt": "The First-tier Tribunal considered whether Sir John Griffin was domiciled in England for tax purposes during the tax years 2013/14 to 2019/20, and held that he was, dismissing his appeal against HMRC's closure notices.",
"judgment_summary": "Sir John Griffin appealed against closure notices issued by HMRC which increased his tax liability for the tax years 2013/14 to 2019/20 by a total of £20,537,671.97, on the basis that he was domiciled in England rather than Ireland during those years (paragraph 1).\n\nThe only issue in the appeal was Sir John's domicile status for tax purposes during the Relevant Years (paragraph 2). HMRC argued that either Sir John's father, Jack, had acquired an English domicile of choice before Sir John reached majority on 1 August 1963, giving Sir John a domicile of dependence that became a domicile of choice at majority, or alternatively that Sir John himself had acquired an English domicile of choice between 1963 and the start of the Relevant Years (paragraph 6). Sir John maintained that he retained his Irish domicile of origin throughout (paragraph 7).\n\nThe Tribunal found that Jack had acquired a domicile of choice in England probably by 1959, and in any event before Sir John attained majority in 1963 (paragraph 181). It followed that Sir John acquired a domicile of dependence in England which continued upon his reaching majority (paragraph 182). The Tribunal also considered, for completeness, HMRC's alternative case and found that, even if Sir John had not acquired an English domicile through his father, he would independently have acquired an English domicile of choice well before 6 April 2013 (paragraph 208).\n\nThe appeal was dismissed and the closure notices were affirmed (paragraph 212).",
"background": "Sir John completed his self-assessment tax returns for the tax years 2013/14 to 2019/20 on the basis that he was domiciled in Ireland (paragraph 1). HMRC opened an enquiry into these returns on 8 January 2016 and issued closure notices under section 28A of the Taxes Management Act 1970 on 22 November 2023, on the basis that Sir John was domiciled in England and Wales in each of the Relevant Years (paragraph 1). The closure notices resulted in a total increase in Sir John's tax liability for the Relevant Years of £20,537,671.97 (paragraph 1).\n\nSir John was born in England on 1 August 1942 to Irish parents (paragraph 3). HMRC accepted that Sir John's father, Jack, had a domicile of origin in Ireland and had not acquired a domicile of choice in England at the time of Sir John's birth (paragraph 3). Sir John's domicile of origin was therefore Ireland, and this remained his domicile until he turned 21 on 1 August 1963, the age of majority at the relevant time (paragraphs 4 to 5).\n\nSir John founded Addison Lee in 1975 and built it into a substantial business, which he sold to the Carlyle Group in April 2013 for consideration including cash and preference shares (paragraphs 75, 104 to 109). Sir John maintained substantial connections to Ireland throughout his life, including two properties in County Kerry, land holdings, investments in Irish businesses (Irish TV and PiPiper), and charitable and community involvement in Ireland (paragraphs 87 to 101, 113 to 125).",
"core_dispute": "The core dispute was whether Sir John was domiciled in England for tax purposes during the tax years 2013/14 to 2019/20 (the Relevant Years) (paragraph 2).\n\nHMRC's case rested on two alternative bases: first, that Jack had acquired a domicile of choice in England before Sir John's majority on 1 August 1963, so that Sir John acquired an English domicile of dependence which automatically became a domicile of choice at majority; or second, if that were not established, that Sir John himself acquired an English domicile of choice at some point between 1 August 1963 and the beginning of the Relevant Years (paragraph 6).\n\nSir John's position was that he retained his Irish domicile of origin at least until the end of the Relevant Years, relying on his enduring emotional and practical connections to Ireland, including property, investments, and community involvement there, and evidence that he and his father had always intended, or hoped, to return to Ireland (paragraphs 7 to 8, 143 to 146).\n\nThe parties agreed on the burden and standard of proof: it fell on HMRC to prove, on the basis of substantial, cogent and clear evidence, on a balance of probabilities, that Jack or Sir John had acquired an English domicile of choice (paragraph 27).",
"court_findings": "The Tribunal reviewed the case law on domicile of choice, including Udny v Udny, Re Fuld, Bullock, Barlow Clowes, Winans, and Musa, among others (paragraphs 9 to 27). It held that abandonment of a domicile of origin is not a separate requirement but a legal consequence of acquiring a domicile of choice, and that the focus should be on whether the propositus formed the necessary intention to reside permanently in the country of residence (paragraphs 158 to 161).\n\nOn Jack's domicile, the Tribunal found that, although Jack retained genuine affection for Ireland, the objective facts of his life, including his long residence in England, his marriage, his business (Sullivan Construction), his family life, and property acquisitions in Kilburn and Barnet, provided clear, cogent and compelling evidence that he had made England his permanent home probably by 1959, and in any event before 1 August 1963 (paragraphs 162 to 181). The Tribunal treated the witness evidence of Sir John and Malcolm regarding Jack's intentions with caution, noting the absence of contemporaneous documentary evidence and the guidance on self-serving statements in domicile cases (paragraphs 173 to 175).\n\nOn Sir John's domicile, the Tribunal found, in the alternative, that by 5 April 2013 Sir John had settled in England in every meaningful sense, having lived there continuously for over sixty years, built his career and business there, married and raised his family there, and organised his social, business and philanthropic life around England (paragraphs 183 to 207). The Tribunal found that Sir John's attachment to Ireland, while genuine, amounted at most to a hope or aspiration rather than a settled intention to return, and that his own evidence acknowledged he had "no detailed plans" to move to Ireland before his involvement with Irish TV, which post-dated the start of the Relevant Years (paragraphs 194 to 199).\n\nThe Tribunal drew an adverse inference from the absence of Rita, Sir John's long-term partner, as a witness, finding that her absence weakened Sir John's case regarding his intentions to relocate to Ireland (paragraphs 200 to 202).",
"outcome": "The Tribunal found that Jack had adopted a domicile of choice in England before Sir John attained majority on 1 August 1963, so that Sir John acquired a domicile of dependence in England which continued as his domicile upon reaching majority (paragraphs 210).\n\nAlthough not strictly necessary given this finding, the Tribunal also concluded, in the alternative, that Sir John had independently adopted a domicile of choice in England before the beginning of the Relevant Years (paragraph 211).\n\nThe appeal was dismissed and the closure notices were affirmed (paragraph 212).",
"tp_method": "",
"major_issues": [
"Whether Sir John was domiciled in England for tax purposes during the tax years 2013/14 to 2019/20 (paragraph 2).",
"Whether Sir John's father, Jack, had acquired a domicile of choice in England before Sir John's majority on 1 August 1963, giving Sir John a domicile of dependence in England (paragraph 6(1)).",
"If not, whether Sir John himself acquired a domicile of choice in England between 1 August 1963 and the start of the Relevant Years (paragraph 6(2)).",
"The correct legal test for the intention required to acquire a domicile of choice, and the relevance of continued attachment to the domicile of origin (paragraphs 13 to 27, 155 to 161).",
"The burden and standard of proof required to establish a change of domicile (paragraph 27).",
"The weight to be given to Sir John's witness statement given his medical incapacity and inability to be cross-examined (paragraphs 35 to 46).",
"The weight to be given to the oral evidence of Liam and Malcolm regarding Jack's and Sir John's intentions (paragraphs 47 to 51, 137 to 142).",
"Whether an adverse inference should be drawn from the failure to call Rita, Sir John's partner, as a witness (paragraphs 147 to 153, 200 to 202)."
],
"tax_categories": [
"Income Tax",
"Tax Administration"
],
"tags": [
"Domicile",
"Domicile of Origin",
"Domicile of Choice",
"Domicile of Dependence",
"Closure Notice",
"Section 28A TMA 1970",
"Burden of Proof",
"Standard of Proof",
"Self-Assessment",
"Witness Evidence",
"Adverse Inference",
"Domicile of Dependence to Majority",
"Ireland",
"Addison Lee"
],
"uncertainties": "The judgment does not specify the exact statutory basis for how domicile affects the tax liability figures cited (e.g. remittance basis provisions), so the precise Income Tax mechanism is not detailed beyond the closure notice figures. The judgment does not mention Capital Gains Tax, Penalties, or other tax categories explicitly, so these have been excluded. The neutral citation and case number appear to be as stated in the judgment header, though this is a hypothetical/illustrative case per the reference label given."
}