Sir John Griffin v The Commissioners for HMRC

Facts

Sir John Griffin, the founder of the private hire business Addison Lee, was born in England on 1 August 1942 to Irish parents. His father, John Griffin senior ("Jack"), had left Glenbeigh, County Kerry in about 1935 to find work in England, enlisted in the Irish Guards, deserted at the outbreak of war and thereafter lived under an assumed name in London, working in construction. Sir John spent part of his infancy in County Mayo with his mother before the family settled in London in 1951 or 1952; he later built Addison Lee, which he sold to the Carlyle Group in April 2013. He completed his self-assessment returns for the tax years 2013/14 to 2019/20 on the footing that he was domiciled in Ireland. HMRC opened an enquiry on 8 January 2016 and on 22 November 2023 issued closure notices under section 28A of the Taxes Management Act 1970 on the basis that he was domiciled in England throughout, increasing his liability by £20,537,671.97. HMRC accepted that his domicile of origin was Irish but contended either that Jack had acquired an English domicile of choice before Sir John's majority on 1 August 1963, or that Sir John had himself done so before the relevant years. Sir John, by then medically unfit to give evidence, appealed to the First-tier Tribunal.