In the run-up to the budget, I have seen claims that as many as one in five people are planning to leave the UK because taxes are too high. If they are, they're in for a shock. The well-off and the wealthy get a great tax deal in the UK that they're going to find hard to replicate anywhere else.
This is the audio version:
This the transcript:
Are the rich really going to leave the UK? You would think that from all the pre-budget discussion and all Rachel Reeve's flight in terror from all the proposals that she once made to tax the rich just a tiny little bit more, that they are all going to flee if ever a single tax is raised upon them. And let me tell you. I don't believe that's true at all.
I did a lot of work on this issue when I was beginning to research the Taxing Wealth Report 2024. In that report, I suggested that the wealthy are undertaxed by £170 billion a year in the UK. Now let's be clear, I never once pretended that this £170 billion could be recovered. And, I did make clear that it was an estimate, and there were lots of assumptions involved.
But let me become a little more precise. Have a look at this chart.
The chart is based upon information produced by the Office for National Statistics, who are the UK's National Statistical Agency, unsurprisingly given their name.
They make it as hard as possible to find most data that you want on anything of use within the UK National Statistics. It's as if they believe that hiding data from view is their sole reason for being. But when I found the information I needed, their data plus that from HM Revenue and Customs, that gave me the chance to put together this chart.
The chart is based upon information from the years 2010 to 2020. In other words, from just after the global financial crisis to before COVID hit: a decade when things were relatively stable in economic terms. And what the chart shows is two things.
The orange line is the effective tax rate on income of groups in the UK. Now, the groups in the UK are divided into deciles. In other words, taxpayers are split into ten groups of equal size. So, given that there are a bit over 30 million taxpayers, there's a bit over 3 million people in each of those deciles. And what I worked out, using official data, was what the likely effective tax rate on the income of people is in those deciles.
Now let's be clear: the incomes are not spread equally by decile. Most of those deciles, up to the 80th to 90th, are earning, well, £50,000 a year and less. It's only the top decile, the top 10%, who are earning £80,000 and more a year, and some of them, of course, earning extraordinary amounts.
But what you will see is the lowest group of income earners have a very high tax rate. It's something like 44%. But let's be clear: that's because quite a lot of their income is not taxable. They are, in a very real sense, an outlier.
For example, students pay quite a lot of tax because, well, they seem to drink quite a lot of booze and smoke quite a lot of fags, in my experience, and some other things that require the consumption of taxes, like just buying basic commodities to live. So, they pay very high rates of tax, but they don't apparently have significant income.
And they're not alone. There are, for example, nontaxable benefits, and those aren't recorded as income for this group. So, that data is a bit distorted, and I accept that. Nonetheless, what is clear is that those on very low incomes do have quite high tax rates.
Then, we go through an area where the tax rates rise very slowly.
For those who are on low incomes, the effective tax rate, the overall tax rate, including all taxes paid - that includes council taxes and VAT and national insurance and alcohol taxes and car taxes and the BBC licence fee, as well as income tax and capital gains tax, and the effective imputation of corporation tax to people, which means in other words, although companies pay it, it is assumed that somebody at the end of the day pays the burden of it - put all those things together and the overall tax rate on people on low incomes is just over 30 per cent.
And you'll see that by the time we get to the ninth decile, those people who are earning reasonable salaries in the UK, then the tax figure gets to around 35 per cent. And it goes up to about 38 per cent in the top group. And on that basis, it is claimed that we have a progressive tax system in the UK.
But, and I make the point very strongly, there is a blue line as well. The blue line represents the rate of tax paid overall on the combined income and increase in wealth of people in each decile group over this same period.
The figures are actually for 2019/20, the last year in the period, but they use the data for the whole period to work out this split between the increase in wealth and the amount of income that each group has.
Over the ten-year period that we're looking at here, the total GDP, that's national income of the UK, was something like £15,775 billion. It's a mighty great sum of money.
Over that same period, however, the increase in the wealth of people amounted to £5,773 billion. Therefore for every one pound of income that was earned over that period, wealth went up by 36. 5p. And I deliberately reduce it to that ratio of increases in wealth to income because that's a number we can comprehend.
Think about it. For every one pound you earned, your income should have gone up by 36.5p. Did it?
It's very unlikely that that was the case for you. And why can I say that? That's because probably you are not in the top 10 per cent of income earners. By definition, you are most likely in the 90 per cent of other people in the UK. And at least half that increase in wealth went to that top 10 per cent. So, when we combine the figures for income and increase in wealth, we come up with very different figures for tax.
And that's because the overall average effective tax rate over the decade for tax on income was 32.9%, roughly a line drawn straight through that orange figure. But if we look at the average rate of tax on wealth, it was just 4. 1%.
In other words, tax was only taxed at a little over 10 per cent of the rate that income was. Therefore, if we skew the rewards from the increase in wealth towards those who are already on high earnings and who are already wealthy and tax them very little, as we do, what you get is the blue line.
The overall effective tax rate on increases on income and wealth, which represent the overall increase in financial well-being arising during the period, falls dramatically as your income rises.
In fact, as you will see, at the very lowest level, there's really no difference. But once we get up to the top group, the effective rate of overall tax is around 22 per cent, which, by the way, was the rate of tax that was paid by Rishi Sunak on his last declared tax return. There is some evidence that this figure might well be right.
And that's what matters. Because people aren't going to run their overall rate of tax is so low only 22%. Because frankly, finding an equivalent rate around the world is going to be immensely difficult for anyone with wealth.
They could do it, they could go to a tax haven and suffer all the miseries of living in such places. I'm always immensely amused when I arrive in Jersey Airport, which I have done in my life, and note the fact that outside that airport there is an enormous array of very expensive cars on sale from various car dealers. You can buy an Aston Martin, a Lagonda, a Rolls Royce, a Bentley, an enormous Jaguar, whatever you wish. The top speed limit on Jersey is 40 mile an hour. What people are ever going to do with these cars on that tiny island, I don't know. The paradox of wealth is there and apparent. They might be incredibly wealthy, but they can't live in these places.
The advantage of the UK is you can live here and you can enjoy your wealth.
Now I stress, these numbers are estimates. They are extrapolations from data and the figures will of course vary. But as I've just noted, Rishi Sunak did pay tax at 22 per cent overall. So, let's be clear, the wealthy are not going to be running away because Rachel Reeves might increase their tax a little bit. That is complete and utter nonsense.
And even if a few did, let me take an example. Suppose Rachel Reeves doubled the rate of capital gains tax. Now at the moment, capital gains tax collects around £15 billion of revenue a year; tiny in proportion to the UK, because only 1 per cent of people in the UK pay capital gains tax. But suppose she doubled that rate so it was the same as the income tax rate on equivalent income. You would expect that she would earn £30 billion of revenue as a result.
Now, some people say they'll leave. And I accept their threat is real. Some people will leave. Suppose that 10 per cent of the wealthy go. Therefore, we won't get tax on 10 per cent of the capital gains that we did previously. So, she doubles the rate and collects £30 billion in theory, instead of £15 billion. But 10 per cent of people go, which means she loses £3 billion. So doubling the rate won't double the revenue. It will increase it from £15 billion to £27 billion.
Would you rather have £27 billion or £15 billion? I know what my answer would be if I was Rachel Reeves, and I know I would double the rate of capital gains tax to bring it into line with income tax and deliver tax justice as a result.
I also know that the revenue I would collect would increase. Simply, straightforwardly, as a matter of fact, it would.
And most people do not manage their capital gains to minimise their tax bill. They manage their capital gains because there's an opportune moment to make money on selling assets at a high price. That's what drives the recognition of capital gains. So, all the nonsense that we are told about the fact that if she increases tax, everybody will leave is, first of all, wrong.
Most of this group are not going to leave because their in-laws are here, their children are here and at school, their ponies are here, their clubs are here, they can't miss their golfing mates, whatever it might be, they won't be going. But also, even if some of them do, we'll still get more tax revenue.
In other words, Rachel Reeves can afford to ignore all of this, all the protestations of the wealthy right now, because they're frankly talking a load of nonsense. They have the most phenomenal deal with regard to taxation in the UK at present, and even if all the recommendations that I put in the Taxing Wealth Report were put into place, they would still be vastly better off with regard to the proportion of their incomes and increases in wealth paid in tax than most people who simply have to work for a living. They're getting a free ride at the expense of the rest of us. They know that. They're not going anywhere.
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Thank you for that excellent summary.
I’m guessing it does not include student loan repayments which to me are an iniquitous tax.
As I have mentioned before, even if people do leave, their assets in sterling necessarily have to stay in the UK, which is the only place sterling assets can actually be spent. If someone moves abroad they have to swap their sterling assets for foreign assets (i.e. a currency exchange). Then that person acquires the sterling assets, and the total assets in the UK remains the same.
I suppose what might happen if a vast number were to leave (which is not going to happen), is that large amounts of foreign exchange transactions would depress the value of the pound.
So, no people are not going to leave, but there’s nothing to worry about if they did; the money stays in the UK.
Let them leave if they wish.
Tim, a point well made.
Further, it could be the case that in disposing of their sterling assets, less wealthy people, who as Richard has shown have a higher effective tax rate, will end up acquiring some of these assets and then pay more tax proportionally on those assets, so the Government tax take might even go up!
Oxford economics is not impartial, it touts it services to business and is not going to spread ideas that undermine the prejudices and dogma of the people that run the companies that pay for those services.
Sorry should have been reply to David
Oxford Economics disagrees with you..https://www.oxfordeconomics.com. and I suggest they are more resourced than you. And more importantly they are not weighed down by dogma in the way you are where comment is rarely impartial.
“Almost two-thirds (63%) of wealthy investors said they plan to leave the U.K. within two years or “shortly” if the Labour government moves ahead with plans to ax the colonial-era tax concession, while 67% said they would not have emigrated to Britain in the first place, according to a new study from Oxford Economics”
I think you will find they utterly weighed down by dogma
Only a fool cannot see that
The data also completely fails the smell test for any sense of reasonableness, but you and they can’t see that
@ David
“…Oxford Economics disagrees with you..https://www.oxfordeconomics.com. and I suggest they are more resourced>>”
More resourced? Richer? Probably. Well paid by vested interests or as they say in Scotland'”Yeah Right”, David.
Hardly anybody is going anywhere and if they do? So What? What are we losing as a nation? A bunch of antisocial rentier capitalists with more money than social conscience.
Any foreign country that will have them is w welcome to them.
And your numbers convince no one. Numbers lie like cameras used to, because people are supposed to believe them to be objective and they never are.
Misguided trolling is my impression. A useful idiot at work. Because YOU are going nowhere. Are you? People I know have headed for sunnier climes for the lifestyle not for tax reasons and none of them are seriously wealthy. They just made a lifestyle choice and can afford to come home when they need/want to.
david
I like your comment ‘ I suggest they are more resourced than you.’. I think you are right and that their ‘opinions’ are bought and paid for.
The rich people saying they will leave the country because taxes are too high, remind me of those kids playing football in a park, who took their ball home when they were losing, so no-one else could play. Childish and selfish.
I remember this was feared in the 1970’s when Labour came in. Apart from a few high profile cases, Michael Caine I think, it didn’t happen. Also, remember, the top rate of tax was 98%.
@Alan Knowles
98%.~
~Unbelieveable isn’t it? Even the Republican, American, Eisenhower approved these high rates of surtax.
Once they’d gone in Thatcher-land (and Reagan-land) the rich became so greedy there was no limit to their expectations. Reducing the tax burden didn’t stop the outrageous growth of upper earners remuneration demands. It read like an invitation and was accepted.
Inflation trickles down even if, as we know, wealth doesn’t. In the end we all pay eventually.
A great imponderable is behavioural response.
Some people will undoubtedly leave the UK, temporarily or permanently. I know some who have already gone. Mostly people without deep roots in the UK and with much of their wealth outside the UK. They have always been mobile and they will go to places like Switzerland or Dubai or Italy where they can have a reasonable standard of life but pay less tax.
Yet others will decide not to come to the UK in the first place. Again I know some people who have changed plans to relocate to the UK, or reduced the amount of time they intend to spend here.
Some people who stay will realise gains now (in the next couple of weeks, before the rates may change). Others will defer realising gains (not sell their house or company, say, at an opportune time, but wait until later, hoping for the rules to change again in their favour, or until they can’t wait any longer).
Does it matter? Probably not. It makes a difference at the margin but this is not predominantly about the numbers. It is about fairness. It doesn’t actually matter much if the changes raise £10 billlion or £1 billion or nothing. Or even “cost” a few billion in reduced revenues, which is a tiny pimple on the £1000+ billion mountain of public spending and tax revenues.
There is a basic simple point that the tax system should not give tax breaks that benefit only the wealthy. The reason why wealthy individuals pay a lot of tax is because they have a lot of income and gains and lots of assets. But the rates they pay are often less than much poorer people. How can we justify that?
Much to agree with
You are absolutely right to call this out. The headline story is all about a small part of the tax package, when it seems to obvious to me that the other tax breaks put money BACK into the the pockets of the rich because all they have to do is point that at out to HMRC.
Again, this cannot be said enough. Tautology is the name of the day.
I as a working person actually pay I think more of a proportion of my earnings as tax than these these people who threaten to leave. For us working stiffs, there is no way out as there seems to be for the asset rich.
But all they’d say is that that was my fault, I haven’t ‘worked hard enough’ (gone and committed daylight robbery somewhere).
I wonder how many rich really do not understand how hard their accountants and lawyers work to actually save them money with tax breaks so that they do think that they are losing out and react like this?
An article in the FT looked at the Norwegian experience.
Those that leave have their assets “marked to market” on exit and capital gains tax is charged on this number. To avoid forced liquidation they have 12 years to pay.
It seems fair to me that tax should be payable on gains while you are in the country…. and this might change the calculus. Leaving now becomes about your future, uncertain prospects for capital gain – not what is already “in the bag”.
I think that is fair…
I arguied for it in 2009 when advising the Treasury on the issue
Richard,
Talk about over-exaggerating your involvement!
You weren’t ’advising the Treasury’, you were a bit part player telling Corbyn and McDonnell what they wanted to hear. But they soon ditched you when they realised what you were like to work with.
At no point did the treasury choose to employ you to offer them advice.
I know, I was there during the period!
Actually, much of the work done on residence in 2009-10 was by me, John Whiting and Bill Dodwell as I recall. I represented the TUC.
Voice of reason
I do not believe that you were there in 2009 when Richard was ‘advising Corbyn and McDonnell’. Why would he have been doing so when they were backbenchers at the back end of the Blair/Brown era? If you were there you would have been aware of this. So you must be a liar.
All true
Polly Toynbee had this yesterday, similarly debunking the idea that the wealthy are aking flight
https://www.theguardian.com/commentisfree/2024/oct/11/super-rich-flee-britain-labour-tax-grab-exit
Her suggestion is feeble though
@ Helen Heenan
I stopped reading Polly Toynbee a long time ago.
I am reassured by Richard’s (current) assessment of her feebleness. I found her so annoying I couldn’t bear the rise in blood pressure. If this is left-wing journalism god-help-us.
She’s a definite has-been in my book. She WAS left, but no longer travels as a fellow with us.
But then she writes for the Guardian which became ‘the Daily Mail for the literate’ many years ago. I presume she writes the guff their editorial policy demands. I expect it pays (moderately) well when you no longer have anything of value to contribute.
I don’t read Larry Elliot either. Sorry, Larry you’re no longer cutting it. (And I’m quite sure you are reading this, because if you ain’t you really have lost it).
Larry does not read this blog very often and has never read BTL comments, ever
As a side link to this article I read a far more encouraging perspective on taxing wealth from a man who is himself wealthy. Despite being published six months ago, the article entitled: “I have a great way to bring down inflation – make millionaires like me pay more tax” by Phil White, the points he made are really worth reading at this link: https://www.theguardian.com/commentisfree/2024/mar/23/inflation-millionaires-tax-taxation-spending-rich-wealth
He writes that: “As a member of the campaign group Patriotic Millionaires UK, I want rich people like me to pay our fair share of tax. And I’m not alone. Nearly 75% of millionaires also want higher taxes on wealth. The Bank of England is right to want to curb inflation. But the idea of squeezing low- and middle-income earners so that millionaires can keep spending on luxury items isn’t the way forward. We urgently need to tackle the root causes of the cost of living crisis, and we can start by introducing higher taxes on wealth.”
Phil White is described as “a former business consultant and engineer, and is a founding member of Patriotic Millionaires UK”. It would seem that this group are supporters of the tax changes laid out in your ‘Taxing Wealth Report’. Let’s hear it for those with wealth and conscience!
What is the evidence that having rich people in a country is actually a benefit? Is their being here detrimental to the country both socially and economically? Is there any actual genuine evidence based research on this, and I don’t mean think tank papers paid for by the rich or opinion based surveys or wealth managers puff touring for business?
You ask a very good question
We assume richness = value and virtuousness
There is little evidence to support that
If what’s important is what people actually do, then I’d say rich people don’t do anything of genuine value. I read an article online, which distinguished different kinds of work, and I think we need to be clear that money is not a measure at all of what someone did for it, or the time it took to get it. The article distinguished between the kind of work that directly benefits someone and the money paid as a fair exchange for that work, and what they called the job of exploitation. They noted that exploiting others can be very hard work, it’s just not work to be admired or allow. Unfortunately, we do allow exploitation across the world and in the UK, hence we end up with rich people. No one in a boardroom ever does the things that people pay for whether that’s making an item or transporting and so on, yet they do take a lot of the money. Exploitation is disguised by language games, it’s often called management or directing or some other title or term and often those exploiting are motivated even to deny to themselves that that’s what they’re doing, justifying the pay difference by saying they have talents and abilities and responsibilities that are being fairly rewarded. Belief in this is a motivated self-deception, and is societally encouraged. And societies lie to themselves continuously, telling themselves how wonderful they and their values are. And even those exploited often believe they are not being, yet the very condition of being an employee is a subjugated position, and exploitation – being paid less than you contribute – is a necessary condition of profit, which is extracted not only from the worker, but also the customer, the resources of the world and society as a whole (externalities). The very system guarantees exploitation will happen whilst simultaneously being euphemised out of consciousness.
I’d say if the rich left, what remained would be far more mutually beneficial. But the UK would still be a toxic, exploitative place to live, because it’s a hierarchical, extractive system. As many here have noted, wealth gushes up for no good reason – rent says nothing about the ability or worth of the asset holder’s contribution, and favourable legislation is not a measure of the beneficiary’s skill. Being rich needs to go, but so do the conditions that allow exploitation. I would argue that, as long as exploitation is allowed, global ecocide will continue, that they are two sides of the same coin. The psychic harm of exploitation will not lead to people willing to make the changes necessary for sustainability and
If what’s important is what people actually do, then I’d say rich people don’t do anything of genuine value. I read an article online, which distinguished different kinds of work, and I think that money is not a measure at all of what someone did for it, or the time it took to get it. The article distinguished between the kind of work that directly benefits someone and the money paid as a fair exchange for that work, and what they called the job of exploitation. They noted that exploiting others can be very hard work, it’s just not work to be admired or allow. Unfortunately, we do allow exploitation across the world and in the UK, hence we end up with rich people. No one in a boardroom ever does the things that people pay for whether that’s making something or transporting it and so on, yet they do take a lot of the money. Exploitation is disguised by language games, it’s often called management or directing or some other title or term and often those exploiting are motivated even to deny to themselves that that’s what they’re doing, justifying the pay difference by saying they have talents and abilities and responsibilities that are being fairly rewarded. Belief in this is a motivated self-deception, and is societally encouraged. And even those exploited often believe they are not being, yet the very condition of being an employee is a subjugated position, and exploitation – being paid less than you contribute – is a necessary condition of profit, which is extracted not only from the worker, but also the customer, the resources of the world and society as a whole (externalities). The very system guarantees exploitation will happen whilst simultaneously being euphemised out of consciousness.
I’d say if the rich left, what remained would be far more mutually beneficial. But the UK would still be a toxic, exploitative place to live, because it’s a hierarchical, extractive system. As many here have noted, wealth gushes up for no good reason – rent says nothing about the ability or worth of the asset holder’s contribution, and favourable legislation is not a measure of the beneficiary’s skill.
“…. put all those things together and the overall tax rate on people on low incomes is just over 30 per cent.
And you’ll see that by the time we get to the ninth decile, those people who are earning reasonable salaries in the UK, then the tax figure gets to around 35 per cent. And it goes up to about 38 per cent in the top group. And on that basis, it is claimed that we have a progressive tax system in the UK”.
It does look progressive, but that is only because we are looking at percentages; an abstraction. The more telling figure to me would be the difference in disposal income available to a person/family for the difference in tax rate between 30% and 38% tax rates. From the perspective of the lower paid, someone with total taxable income of, say £25,000, and a 30% tax rate, then very crudely they have disposable income left of £336 per week. From the perspective of the higher paid, someone with total taxable income of, say £75,000, and a 38% tax rate, then very crudely they have disposable income left of £894 per week. My point is that in a cost of living crisis, and a serious financing situation for government, the adverse impact of an increase in tax is exacerbated far more for the lower paid (every £1 is critical, and 8% tax difference is critically worth £40 per week), because their capacity to absorb a fall in disposable income, without harm to their family is much harder to contemplate. There is no doubt a penalty for the higher paid, but even with an 8% differential in tax rates, I would argue it is not sufficient to deliver material harm. £40 per week is critical for the lower paid, but such a quantum per week has far less material impact for the highly paid – and it is the material impact on the low paid that should be critical at this juncture for government, not the mere fact that the higher paid rightly pay more tax. It is the point at which a penalty in the indulgences of life turns into more material harm to families that should matter to government first. As it stands, to avoid the relatively minor inconvenience of some additional tax on the higher paid for a temporary period, the government would appear to prefer to increase taxes on those already much closer to experiencing material harm in their families standard of living, in order not to be vilified by a Conservative-Neoliberal press (which is never going to change, whatever the suffering inflicted); in which case the Labour government will simply have failed its basic responsibility, and should not be in office.
Yes John. The usual measures of inequality and poverty – relative and/or absolute are not really up to the job – so its good the JRF and others have been looking at ‘material deprivation’ and/or ‘destitution’ – literally not being able to access food, shelter , warmthetc.. These might be envisaged as tipping points – rather than the implied smooth descent down an income distribution
@ John S Warren
Sometimes it’s not about percentages is it?
But sometimes it is.
And the person who tells the story gets to choose the language of the narrative. To suit their purpose.
In my view, disposable income is not what is left after someone pays tax, but what remains after someone pays their rent/mortgage, for food, water, heat, light, since these are unavoidable costs. If we took these into account, then the difference between someone paid £25k and someone paid £75k becomes much starker. For some people, they have less than nothing left at the end of the month, because of the cost of survival. In my view, forcing people to use money and then pegging it to survival is a pretty terrifying, cruel, coercive and morally repugnant thing to do, and particularly so when there are those amongst us who can refuse because they’ve got enough to last them a lifetime (or even many thousands of lifetimes). It’s why I support a UBI, I don’t believe it’s just to make anyone work for what they can’t live without, it snacks too much of indentured servitude, if not rubbing up against slavery. And there’s no escape. It’s excruciating.
A perfectly fair point, but I wished to make the essential underlying point with some clear, simple analysis and without writing an essay.
I also like the idea of ‘tipping points’ and using measurements that discover where they are (nothing is perfect in this field); but ensuring people are not driven over the edge. Mr Broadbent is right; we do our politics as if there are smooth ascents and and smooth descents. There are neither; but descent is worse. After Deng Xiaoping, the architect of China’s modern rise to economic superpower rose to power, he talked about how much harder it was to face the crises of descent (from his own bitter experience), over the problems of ascent.
If taxes are not needed for funding and the very rich mainly live off the productive capacity of the workers then surely them leaving the country just frees up fiscal space for government spending? Or am I missing something?
Taxes are needed to cancel money spent into the economy
But if the purpose of the taxes is to remove the money to prevent it being spent on stuff the government might also bid on, then the rich simply removing the money by vacating themselves has the same effect as taxing it out of existence, no?
No
Sorry, but you are entirely missing the point
The rich leaving does not change sterling circulation necessrily
Richard,
“Taxes are needed to cancel money spent into the economy”
Rachel Reeves and chancellors before her knew this. The rich get the money and the poor get to pay it back through the tax system. (On PAYE with no possibleity of cunning accountants to advise them)
That is how it works isn’t it?
Except in enlightened times and they are few and far between.
Who is paying back the 2008 eight billion of QE? Not the people who benefitted from it.
And we, the rest of us, are paying for it. but it’s just that it isn’t on the real government balance of payments bill except when it suits the government to pretend it is. What else is ‘austerity’ about?
Unfortunately they probably wont
My response to Richard’s question is as most people on here seem to suggest most of the rich won’t leave. But blimey their advisors are quite scared aren’t they.
Do Tax advisors need to pay a licence fee to Govt to undertake their work? If not perhaps we should introduce one.
Tax advisers do not even need to be registered in all cases.