Thousands of tax exiles remain in line for huge bills from the taxman following a landmark court ruling.

Paul Malin, Director of Tax Investigations at the Birmingham office of BTG Tax, part of the Begbies Traynor Group, said they needed to be ultra cautious about such matters as social and family ties.

In an important test case, the Appeal Court ruled in favour of HM Revenue & Customs in refusing Robert Gaines-Cooper non-resident status and presenting him with a reportedly £30 million retrospective tax bill.

The judges said he had never qualified for an exemption from UK taxes.

Mr Malin said: "There are many pitfalls lying in wait for the unwary - from family ties, children remaining in UK schools, membership of UK clubs such as golf and gym clubs to the accounts where your money is kept.

"I suspect there are an awful lot of people in the same situation as Mr Gaines-Cooper."

The globe-trotting businessman insisted he had been domiciled in the Seychelles for more than 30 years and had religiously kept to the taxman's published requirements by spending no more than 91 days per year in the UK.

But the judges - ruling on HMRC's most recent guidance on residence and domicile policy, known as HMRC 6 - said that England had remained "the centre of gravity of his life and interests". HMRC 6 was updated in February 2010 and replaced their previous guidance contained in IR 20 on the same matter but differs is certain significant areas of interpretation of the law in this area and how income and gains may be taxed in the UK.

Mr Gaines-Cooper had never cut his ties with Berkshire, where he grew up, and Oxfordshire, where the court ruled that his home, near Henley, continues to be his main residence. He had failed to show "a distinct break" from his social and family ties in the UK.

"There is a distinction between being non domiciled and non resident in the UK for tax purposes. Just to confuse matters further, a person can be resident in more than one country at the same time."

In this particular case it was important for Mr Gains-Cooper to prove that he was non resident at all times. That does not mean you are not allowed to visit the UK at all. However, it is down to the taxpayer to ensure that such visits do not form a regular pattern and then potentially jeopardise any non resident tax status."

The entrepreneur, in his 70s, began a successful juke box business venture in England in 1958, and subsequently established companies across the world. His will had been drawn up under English law and his son had gone to an English school.

"This is where such ties can get complicated and it is important that detailed records are kept of each and every visit" said Mr Malin.

"If you have never really left the UK then in the light of this case, the tax man may come looking for you."

"Simply saying that you live and work overseas will not put off the tax authorities," he cautioned.

For more information about Begbies Traynor, please visit their website here: www.begbies-traynorgroup.com