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A place of abode in the UK

The word 'reside' was defined by the Oxford English Dictionary in 1928 as meaning 'to dwell permanently or for a considerable time, to have one's settled or usual abode, to live in or at a particular place', and was referred to in the case of Levene¹. The definition remained unchanged in 2009². Having a place of abode in the UK (referred to as 'living accommodation' in ITA 2007, ss 831(1) and 832(1)) was thus an indicator of residence up to 2012/13 (and continues to be used as a UK tie in the statutory residence test from 2013/14 onwards, see E6.102E).

However, there was no requirement that this accommodation or place of abode had to be a house. In Bayard Brown v Burt³ the Court of Appeal considered the case of an American who had lived for 20 years in a yacht moored within English territorial waters, and one which was at all times ready to depart. The court rejected contentions