Sir John Griffin v The Commissioners for HMRC
Decision date: 15 September 2026
Neutral citation: [2026] UKFTT 1319 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This appeal concerned whether Sir John Griffin was domiciled in England or Ireland for tax years 2013/14–2019/20. The Tribunal found his father acquired an English domicile of choice before Sir John reached majority—meaning Sir John acquired an English domicile of dependence—and alternatively found Sir John had independently acquired an English domicile of choice before 6 April 2013. The appeal was dismissed and HMRC’s closure notices were upheld.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: low
The Tribunal applied that a domicile of choice requires an intention to reside in the relevant place for an unlimited time and that abandonment of the domicile of origin is the legal consequence of such intention; the party asserting a change of domicile bears the burden of proving it by clear, cogent and compelling evidence on the balance of probabilities. Emotional ties, habitual visits or ownership of property in the domicile of origin, without more, do not prevent acquisition of a domicile of choice elsewhere.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal noted that declarations of intention must be corroborated by conduct and that self‑serving statements or impaired recollection reduce probative weight. It also observed that tribunals may draw adverse inferences from the unexplained absence of an expected witness and that medical incapacity can justify admission of a written statement while limiting its weight.