Taxing decision: a UK tribunal found largely in favour of British tax authorities in a legal battle with a Bermudian investment companyA Bermudian investment company has lost a long-running tax dispute with UK tax authorities after a tribunal ruled that, despite being incorporated and administered in Bermuda, its central management and control was exercised from Britain for almost two decades. However, the tribunal also ruled in favour of Mr Ciardi on one issue, finding that His Majesty’s Revenue and Customs had failed to prove the company’s conduct was deliberate. The case stemmed from a disclosure made by Mr Ciardi under the Liechtenstein Disclosure Facility in 2012. HMRC argued that the Bermuda directors effectively rubber-stamped decisions already made by Mr Ciardi from the UK, making the company UK tax resident despite its incorporation in Bermuda. While Cogefin lost the central issue in the case, the tribunal found that the company’s actions with regard to UK tax were not “deliberate”, because the directors genuinely believed the company was not UK resident.