Thousand of rich UK citizens living abroad as tax exiles may find they have to pay UK taxes after all.

The Court of Appeal has upheld the right of HM Revenue & Customs to tax a businessman, Robert Gaines-Cooper, who has lived in the Seychelles since 1976.

The judges said that he had never been exempt from UK taxes as a non-resident citizen.

Although he had abided by the rules not to spend more than 91 days here, he had still not cut his ties with the UK.

Mr Gaines-Cooper may now have to pay a tax bill of £30m, for the years from 1993 to 2004.

A key feature of the Revenue’s old guidance on whether someone was resident in the UK for tax purposes – known as IR20 – was whether they spent more than 91 days here.

“If you read the old guidance at face value, as most of us did, and you spent less than 91 days here, you would have been treated as a tax exile,” said Mike Warburton of accountants Grant Thornton, who was an expert witness in the case.

However, the three Appeal Court judges ruled that it had always been the case that any would-be tax exile, such as Mr Gaines-Cooper, first had to show they had really left the country. BBC.

Now let’s hope the Supreme Court upholds the decision – it’s about time these tax dodgers paid tax.