Addison Lee Founder Loses £20.5m Domicile Fight With HMRC

Sir John Griffin built Addison Lee into one of London's best-known minicab firms. He has now lost a tax fight that could cost him £20.5 million. The First-tier Tribunal has ruled against the entrepreneur, finding he owes HMRC that sum in additional UK tax accrued between 2013 and 2020. Griffin had argued he was domiciled in Ireland through his parents, which he said entitled his foreign investments to preferential tax treatment. The tribunal disagreed, as reported by PHTM.

Judge Michaela Snelders found that Griffin's father had likely acquired an English domicile by 1959, and that Sir John inherited it automatically. That inherited domicile, not the Irish one Griffin claimed, was the basis for the tribunal's ruling against him. Griffin retains the right to appeal.

The case turns on the old domicile-based regime for inheritance tax, which the government scrapped in April 2025 in favour of residence-based tests. The ruling suggests HMRC will pursue large domicile disputes to tribunal even after the regime that created them has been abolished.

For offshore bond and PPLI policyholders, the practical point is that a different form now governs the test HMRC applies. HMRC's D31a form is now the mechanism by which a settlor or transferor declares their long-term UK residence status for chargeable events on or after 6 April 2025, and it is this declaration, not a domicile claim, that determines whether a policy's value sits inside or outside the UK inheritance tax net. Families who still rely on domicile status, rather than the newer residence tests, as the basis for their estate planning should take note.

Griffin's case predates the new regime, but the tribunal's focus on decades-old family history illustrates the kind of dispute the domicile rules produced. The tribunal sifted through his London roots, his Arsenal season ticket, his English golf club memberships and his father's move to London in the 1930s before concluding that Sir John had chosen England as his permanent home.

Updated on 14 October 2026: this article was revised and re-checked against its sources.

Sources

Addison Lee founder Sir John Griffin loses £20.5 million domicile fight with HMRC (PHTM, 12 Oct 2026)