By claiming non-dom status in the Far East, he is able to claim tax relief on offshore investments.
But a judge at a tax tribunal in the Royal Courts of Justice asked for more detail on his lifestyle.
HMRC’s lawyer Christopher Stone said it needed to “look at what he had done with his life, at what life had done to him and his inferred intentions”.
Derby-born Mr Gulliver returned to the UK in 2002 on a two-year project for HSBC. He later became chief exec, earning £8million in 2013 and £7.6million the following year.
The inquiry relates to the year to April 2014. He insists he does pay UK tax on his HSBC earnings.
Mr Gulliver was quizzed in the Commons in 2015 by MP Margaret Hodge.