The First Tier Tribunal (FTT) ruled in favour of Jonathon Oppenheimer dismissing the discovery assessments of £10.1m from HMRC for the tax years 2010-17 stating that Oppenheimer was a treaty resident of South Africa and not the UK during the relevant periods.

HMRC first opened an inquiry into Oppenheimer’s tax affairs in January 2013 and in March 2019 issued closure notices under the Taxes Management Act 1970 in relation to tax years 2010-11, to 2016-17.

The closure notices were predicated on remittances made to Oppenheimer by the Harry Oppenheimer Family Continuity Trust which makes grants to public benefit organisations and institutions, principally in the education sector. The total remittances in this period were £20.1m with the additional tax revenue for HMRC estimated at £10.1m.