In the long-running 20-year case, the Upper Tribunal overturned the First Tier Tribunal’s (FTT) decision and rejected Hargreaves appeal against a discovery assessment of £84m for the disposal of Matalan shares worth £231m in 2000.

Hargreaves was the major shareholder in Matalan and submitted his 2000-01 self assessment tax return on the basis that he was not a resident or ordinarily a resident in the UK.

He took advice from his accountants PwC and moved to Monaco in 2000 to ensure that he was no longer a resident in the UK for tax purposes, this meant he could dispose of shares without becoming liable for capital gains tax (CGT).