Raj Sehgal and Sanjeev Mehan are UK residents but non-domiciled individuals (non-doms). At the time of the HMRC inquiry in dispute, they were part owners (38% each) of Internacionale Retail, a high street and online fashion brand, which collapsed in 2019.

The appeal concerned whether Sehgal and Mehan were liable on the remittance basis for certain payments made by an offshore company controlled by them to a third party offshore company under chargeable gains rules.

Both went to the First Tier Tribunal (FTT) after HMRC decided that tax was owed on payments between companies held offshore in which shares were sold to and from by the pair.