Mr Botnar, who has lived as an exile in Switzerland for the past five years following a raid on Nissan UK headquarters by the Inland Revenue in 1991, said he would appeal the judgment. The ruling follows a decision by the Revenue to abandon the prosecution of 84-year-old Mr Botnar on charges of tax fraud and lift two arrest warrants.
Mr Botnar said he found the latest ruling "highly creative and the product of an inventive mind, bearing no resemblance to reality".
Mr Botnar has already paid pounds 59m to the Revenue in settlement of all its outstanding tax claims against Nissan UK. He intends to return to Britain probably early in the new year.
The latest judgment follows a two-day hearing in the High Court last month which found Mr Botnar was personally liable for tax on the dividends paid into the trust between 1974 and 1990.
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