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Category Archives: Domicile

The new domicile rule won’t work

26-Jun-08

KPMG have published a guide to the new domicile rule. It includes this fascinating flow chart:

I am not going to argue with one little bit of that. The fact is that it is not what is said that matters here, it is what is not said that matters.
There are two serious omissions. The first is […]

The UK: no place to quit

17-Jun-08

Two curious reports this morning, both covered by the FT. The first says:

Britain is the most popular destination in Europe for investment by foreign companies , according to a survey published today - and is likely to remain so for years to come.
The KPMG survey of large multinational companies from 15 leading economies found that […]

What KPMG demands KPMG shall have.

16-Jun-08

I overlooked this last week in the FT:

A partial climbdown on the new “non-dom” tax regime concerning advisers was signalled yesterday by the Treasury in a move designed to stop parts of the private banking industry relocating offshore. In an amendment to the finance bill, the Treasury proposed an exemption for fees paid by non-doms […]

Abolishing the domicile rule could have paid for this

11-Jun-08

The Guardian has reported that:

Child poverty in Britain has increased for the second year in a row, government figures revealed yesterday, putting Labour’s target to halve it by the end of the decade in jeopardy.

The estimated cost of getting on track now is £2.7 billion a year. That could have been raised by completely abolsihing […]

It’s not just Switzerland that abuses human rights

16-May-08

There is another dimension to the story I noted earlier today about Switzerland’s infringement of a Swiss banker’s human rights through the promotion of banking secrecy.
Elmer is right that tax law can infringe on people’s human rights. But it’s not just Switzerland who does this. The UK does too.
The UK’s domicile rule infringes my human […]

Will they ever give up?

25-Apr-08

It’s fascinating to note that Simon Mckie has written in Taxation magazine saying:
The new non-domicile tax regime has been cobbled together and will be bad for UK plc

I’d have thought by now that those supporting the non-dom cause would have seen that the writing was on the wall, but apparently that’s not the case, even […]

Tax haven Britain, in business, but not for long

18-Apr-08

The FT has reported that:

Britain is once again eligible to market itself as a tax haven following recent concessions to “non-dom” residents, according to a firm of advisers.
Grant Thornton’s stance reflects a renewed determination to restore the UK’s image as an attractive place for foreigners to settle, amid fears that its appeal has been permanently […]

Putting the non-dom whingers in their place

14-Mar-08

The FT has done itself little credit over the last few weeks with a mass of letters and commentary supporting the tiny non-domiciled elite who live in this country. A great many people have commented to me at how sickening they have found this.
But it did not please the non-doms despite this. On Wednesday they […]

So near, but so far from catching private equity

12-Mar-08

The Budget contains revisions to the rules for employment related securities relating to people who are resident but not ordinarily resident in the UK. These rules get so close to making the private equity carry chargeable to income tax for some non-domiciled people.
But then you have to remember that the BVCA rules deem the carried […]

This one is going to cause some fun

12-Mar-08

The Budget notes say (page 246) that:

Transfer of Assets Abroad
27. Anti-avoidance legislation designed to prevent individuals from avoiding
income tax by transferring assets abroad will be amended to ensure these
anti-avoidance provisions apply to non domiciled individuals. The
remittance basis will apply to remittance basis users.

This is a massive change. It effectively says that once a non-domiciled person […]

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