The Supreme Court has held that HMRC's IR20 guidance on residence required taxpayers to make a distinct break to become not resident and not ordinarily resident in the UK, unless they left the UK for full-time work abroad, and that HMRC did not change its practice in 2004-05. The court dismissed the taxpayers' judicial review appeals by a majority of four to one. This is a detailed legal update on the decision. (R (Davies and another) v HMRC; R (Gaines-Cooper) v HMRC [2011] UKSC 47.)