The new domicile rule won’t work

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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 any attempt to tackle the issue of the long-term low-paid migrant worker. Perhaps that is because they cannot afford tax advice.

The second is the glaringly obvious fact that this model is not sustainable.

I suspect that the first budget made after the 2010 general election, whoever is then in power, will see the rule change. It's my bet but it will go, to be replaced by a better, statutory, definition of residence.