The appellant, Knights Developments Limited (KDL) is a luxury property developer which buys up land across the UK and builds high end properties with a current site in the Chilterns featuring mansions in the £5-15m price bracket. The company is registered in the Isle of Man and the dispute with HMRC arose over the allocation of taxing rights between the UK and the Isle of Man over profits and corporation tax liability.

KDL was incorporated in the Isle of Man on 27 November 2001 (originally under the name Invertay Limited). It is and has at all material times been resident in the Isle of Man for tax purposes, and has never been resident in the UK.