The First-tier Tribunal has dismissed an appeal against closure notices increasing Sir John Griffin's income tax liability by over £20m for the years 2013/14 to 2019/20, holding that he was domiciled in England throughout: Sir John Griffin v HMRC [2026] UKFTT 1319 (TC).

Sir John, the founder of Addison Lee, was born in England in 1942 to Irish parents and had an Irish domicile of origin. The Tribunal found that his father had acquired an English domicile of choice before Sir John reached majority in 1963, so that his domicile of dependence became a domicile of choice at that point, and would in any event have found that Sir John himself acquired a domicile of choice in England before the years in issue.

On that alternative case, the Tribunal attached significance to the sale of Addison Lee in 2013. Until then, the business explained why Sir John continued to live and work in England. After it, he had the means and the freedom to move to Ireland and did not, instead acquiring further interests in England. His attachment to Ireland, his homes and patronage there and his hope of returning one day never hardened into the settled intention which the Tribunal concluded the law requires. Sir John’s evidence was that he had no detailed plans to move before his involvement with Irish TV, which the Tribunal concluded post-dated the start of the years in issue. The Tribunal concluded that Sir John had, at most, a hope that he might return to Ireland which existed at 5 April 2013.

Two further points are of wider interest. The Tribunal accepted HMRC's submission that abandonment of the domicile of origin is not a separate requirement but the consequence of acquiring a domicile of choice, and is not to be confused with abandoning the country itself: a person may retain property, ties and affection there and still lose it as a domicile.

The Tribunal also drew an adverse inference from the failure to call Sir John's partner of twenty years, no reason having been given for her absence, notwithstanding that the burden of proof lay on HMRC.

Christopher Stone KC and Bayo Randle appeared for HMRC.

Akash Nawbatt KC and Colm Kelly appeared for Sir John Griffin, instructed by Blick Rothenberg Limited.

A full copy of the decision can be found here.