HMRC has failed to overturn a First-tier Tax Tribunal (FTT) judgment that two non-doms, Raj Sehgal and Sanjeev Mehan, should not be liable on the remittance basis in respect of payments made by an offshore company controlled by them to a third-party offshore company, causing the two to be released from liability under an indemnity they had given on a sale of shares in their UK business. 

In 2010, the taxpayers' Jersey company sold shares in Visage Group, a UK c...