The increased focus on wealthy individuals by HM Revenue and Customs (HMRC) has resulted in a dramatic rise in the tax yield from their investigations (reported to be £373 million in 2008/9 compared with £81 million the previous year).

Complex avoidance schemes and the use of non-resident income sources have been subject to sustained attack by HMRC and this is expected to continue, with the UK tax authorities increasing information sharing with those of foreign countries and requiring disclosure of foreign accounts.

HMRC will also be looking forward to reaping additional income as the Court of Appeal has rejected the argument put forward by a wealthy Seychelles resident, finding that even though for many years he spent fewer than 91 days in the UK (and thus, in his view, maintained non-resident status), his residence for tax purposes was his home in Oxfordshire.