Abstract
In this note, the author discusses the case of Lynette Dawn Yates v. Commissioners for H M Revenue and Customs (2012), in which the First-tier Tribunal applied the former residence test under UK domestic law, as well as article 13(4) of the Spain-United Kingdom Income and Capital Tax Treaty (1975), in determining an appeal brought by Mrs Yates, who divided her time in the years in question between Spain and the United Kingdom.
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