Benoît d'Angelin, originally from France but currently residing in Italy, was a UK resident in 2016 but not UK-domiciled. He had recently opened a company in the UK called d'Angelin & Co, investing £1.5m of his foreign income into the business.

This was done so with guidance from legal advisers who found it would fall under business investment relief and therefore would be exempt from any tax.

A director’s loan account was set up for d’Angelin, which he racked up £75,000 in personal expenses, which included the hiring of private jets, a 79p iTunes subscription and gifts for his wife.

HMRC saw this as an ‘extraction of value contrary to the “remittance basis” provisions in Part 14 of the Income Tax Act 2007, and section 809VH in particular’. This led to HMRC denying the business investment relief for the entire £1.5m, serving d'Angelin with a tax bill of £675,000.

A closu