Introduction - Revision history

Ruth Shaw: /* Simplification/complification */

2026-10-21T13:31:50Z

‎Simplification/complification

Ruth Shaw: /* Simplification/complification */

2026-10-21T13:31:25Z

‎Simplification/complification

Ruth Shaw at 13:29, 21 October 2026

2026-10-21T13:29:38Z

Ruth Shaw at 11:18, 18 September 2026

2026-09-18T11:18:26Z

Ruth Shaw: /* Co-authorship */

2026-08-05T09:51:58Z

‎Co-authorship

Ruth Shaw at 08:36, 31 July 2026

2026-07-31T08:36:27Z

Ruth Shaw at 09:11, 21 April 2026

2026-04-21T09:11:30Z

Ruth Shaw at 07:56, 21 April 2026

2026-04-21T07:56:10Z

Ruth Shaw at 07:54, 21 April 2026

2026-04-21T07:54:41Z

Ruth Shaw at 13:37, 20 April 2026

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 :The UK tax code is widely cited as being the longest in the world”.<ref>It is hard to empirically assess the claim that the UK has the longest tax code in the world, and OTS made no attempt to do so.  But if any readers are aware of other serious contenders for that title, I would be interested to hear.</ref>
-This claim had been made at least since 2010.<ref>For older references see the Introduction to the 2016/17 edition of this work.</ref>  In recent years Parliament added:<ref>Finance Act page counts are a rough proxy for the ever growing complexity of the UK tax system, but not an altogether bad one.  A (slightly) better proxy would also consider secondary legislation and HMRC guidance; and, perhaps, case law; then the page counts would multiply the Finance Act numbers set out here tenfold.<br/>
+This claim had been made at least since 2010  and continues to be made regularly, though never with formal evidence to back it up.<ref>For a recent example, see the ICEAW announcing the “Future of Tax Commission” (Oct 2026) and which claimed that the UK has “the longest and most complex tax code in the world”.
 For a discussion of the multidimensional concept of tax complexity, see Tran-Nam and Evans, “Towards the Development of a Tax System Complexity Index” (2014) Fiscal Studies Vol 35 p.341.<br/>
 OTS have published two (somewhat simplistic) discussions of tax complexity:
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-The OTS estimated HMRC guidance at 90,000 pages in 2018;<ref>OTS, “Guidance for taxpayers: a vision for the future” (2018) para 1.21.  These pages have assuredly not been printed or counted.  Quantification raises methodological issues which deserve a short essay to itself.  We have reached the stage where the amount of HMRC guidance is impossible to quantify: the words are uncountable.  Within the limits of guesswork, and assuming 500 words per page (single spacing), the figure of 90,000 pages seems to me to be on the low side.  There are 150 HMRC Manuals, just for a start.
+The OTS estimated HMRC guidance at 90,000 pages in 2018;<ref>OTS, “Guidance for taxpayers: a vision for the future” (2018) para 1.21.</ref> however the figure was calculated, if it was calculated,<ref> Quantification raises methodological issues which deserve a short essay to itself.  We have reached the stage where the amount of HMRC guidance is impossible to quantify: the words are uncountable.  Within the limits of guesswork, and assuming 500 words per page (single spacing), the figure of 90,000 pages seems to me to be on the low side.  There were 217 HMRC Manuals in 2017,  just for a start (though the number of manuals is also not a measure of the amount of guidance).<br/>
 Perhaps the focus of enquiry should be whether HMRC guidance is too short, because 90,000 pages would not be sufficient to do justice to the topic. The legislation, measured by pages of the Orange & Yellow tax handbooks, can be counted and amounts to 23,374 pages in 2025/26 (that does not include DTAs, which would be another 3,000 pages).  The Tax Cases reports, which began in 1875, and ceased publishing in 2014, reached 82 volumes and did not cover VAT. </ref> it will have grown considerably since then.  This guidance was “not comprehensive” - something of an understatement; but according to the OTS “real life cannot be reduced to a neat description in a few (!) pages of writing”.<ref>Para 1.24.</ref>
-Perhaps the focus of enquiry should be whether HMRC guidance is too short, because 90,000 pages would not be sufficient to do justice to the topic. The legislation, measured by pages of the Orange & Yellow tax handbooks, can be counted and amounts to 23,374 pages in 2025/26 (that does not include DTAs, which would be another 3,000 pages).  The Tax Cases reports, which began in 1875, and ceased publishing in 2014, reached 82 volumes and did not cover VAT.</ref> however the figure is calculated, it will have grown considerably since then.  This guidance was “not comprehensive” - something of an understatement; but according to the OTS “real life cannot be reduced to a neat description in a few (!) pages of writing”.<ref>Para 1.24.</ref>
 It is easier to ''talk'' of simplification.  In the ill-fated “mini” budget of October 2022:

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−	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/f/f6/~~20260419085405~~%~~21FD_Introduction_%282~~%29.pdf Introduction And What's New]	+	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/6/6d/FD_Introduction_%281%29.pdf Introduction And What's New]

	==Abolition of domicile and scope of this work==		==Abolition of domicile and scope of this work==

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 These names will be familiar to readers: Rebecca as the moderator of the online edition of this work; Mary as co-author of my ''Taxation of Charities''.
-If any readers are attracted to the challenge of adopting a chapter or section from this work please contact the author.
+If any readers are attracted to the challenge of adopting a chapter or section from this work, please contact the author.
 ==A statute-focussed approach==

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 To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/f/f6/20260419085405%21FD_Introduction_%282%29.pdf  Introduction And What's New]
-==Abolition of domicile and scope of this book==
+==Abolition of domicile and scope of this work==
 This work aims to set out a comprehensive discussion of private client taxation.  This is a wide subject, or set of subjects, but in taxation, as in life, everything is connected.
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 ==Co-authorship==
-This book has always benefited from comments and contributions from readers and discussions with my colleagues in chambers.  It has now grown beyond my ability to maintain it all.  The following chapters are now in the good hands of junior members of Old Square Tax Chambers:
+This work has always benefited from comments and contributions from readers and discussions with my colleagues in chambers.  It has now grown beyond my ability to maintain it all.  The following chapters are now in the good hands of junior members of Old Square Tax Chambers:
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 These names will be familiar to readers: Rebecca as the moderator of the online edition of this work; Mary as co-author of my ''Taxation of Charities''.
-If any readers are attracted to the challenge of adopting a chapter or section from this book please contact the author.
+If any readers are attracted to the challenge of adopting a chapter or section from this work please contact the author.
 ==A statute-focussed approach==
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 When that appeared in 2011 it seemed extraordinary.  But nowadays no professional body issues any statement or guidance without a disclaimer.<ref> For instance, the Law Society likewise issue a disclaimer for their Practice Notes: The standard form is:
-:“While care has been taken to ensure that they are accurate, up to date and useful, the Law Society will not accept any legal liability in relation to them.”  </ref>   Similarly, and ''a fortiori'', the views expressed in this book are put forward for consideration only and are not to be relied upon.  Neither the author nor the publisher accept responsibility for any loss to any person arising as a result of any action or omission in reliance on this work.  But could anyone have thought that a claim might arise in absence of this disclaimer?
+:“While care has been taken to ensure that they are accurate, up to date and useful, the Law Society will not accept any legal liability in relation to them.”  </ref>   Similarly, and ''a fortiori'', the views expressed in this work are put forward for consideration only and are not to be relied upon.  Neither the author nor the publisher accept responsibility for any loss to any person arising as a result of any action or omission in reliance on this work.  But could anyone have thought that a claim might arise in absence of this disclaimer?
 ===A note to the lay reader===
-This book is not intended as a self-help guide, and is addressed to tax practitioners.  In earlier editions I said: “... but it is readable for a lay person.”  I think that is still true, though the text is more daunting than when I first wrote those words, because the law has become more complicated.   However, initiation in these matters must often be by the taxpayer.  If you wish to research this subject in depth, and so take more control of your own tax affairs, read on.  But for implementation you will need to find professionals to advise you. Self-help guides extol “the benefit of bypassing expensive lawyers”; but the bypass may prove the more expensive route in the long run.
+This work is not intended as a self-help guide, and is addressed to tax practitioners.  In earlier editions I said: “... but it is readable for a lay person.”  I think that is still true, though the text is more daunting than when I first wrote those words, because the law has become more complicated.   However, initiation in these matters must often be by the taxpayer.  If you wish to research this subject in depth, and so take more control of your own tax affairs, read on.  But for implementation you will need to find professionals to advise you. Self-help guides extol “the benefit of bypassing expensive lawyers”; but the bypass may prove the more expensive route in the long run.
 ===Edition history===
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-This book was called <i>Taxation of Foreign Domiciliaries</i> for 9 editions; it changed to <i>Taxation of Non-Residents and Foreign Domiciliaries</i> from the 10<sup>th</sup> to the 23<sup>rd</sup> edition and to ''Kessler on Private Client Taxation'' from the 24th edition.<ref>The text of earlier editions is available on [https://privateclienttax.co.uk/index.php/Archive_editions earlier editions] is available on ''https://www.privateclienttax.co.uk'' </ref>
+This work was called <i>Taxation of Foreign Domiciliaries</i> for 9 editions; it changed to <i>Taxation of Non-Residents and Foreign Domiciliaries</i> from the 10<sup>th</sup> to the 23<sup>rd</sup> edition and to ''Kessler on Private Client Taxation'' from the 24th edition.<ref>The text of earlier editions is available on [https://privateclienttax.co.uk/index.php/Archive_editions earlier editions] is available on ''https://www.privateclienttax.co.uk'' </ref>
 == Footnotes==
 <references/>

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−	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/2/2b/~~FD_Introduction_~~%282%29.pdf Introduction And What's New]	+	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/f/f6/20260419085405%21FD_Introduction_%282%29.pdf Introduction And What's New]

	==Abolition of domicile and scope of this book==		==Abolition of domicile and scope of this book==

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−	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/e/e0/~~FD_Introduction~~.pdf Introduction And What's New]	+	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/2/2b/FD_Introduction_%282%29.pdf Introduction And What's New]

	==Abolition of domicile and scope of this book==		==Abolition of domicile and scope of this book==

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 ==Abolition of domicile and scope of this book==
-In the 2025/26 edition of this work I said:
+This work aims to set out a comprehensive discussion of private client taxation.  This is a wide subject, or set of subjects, but in taxation, as in life, everything is connected.
 is a year that will be remembered in tax history.  It announced a set of reforms:
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 This is the most important change in UK taxation since the introduction of CGT/CT in 1965, VAT in 1973, and CTT in 1974, ... It will take some years to work out its consequences.
-The reader will find the results of the first year’s work on the topic, though there is no doubt much more to be thought about, and the FA 2026 (in part retrospective to 2025) adds to the task.
+There is no doubt more to be thought about, and the FA 2026 (in part retrospective to 2025) adds to the task.
 ==Co-authorship==
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 HMRC have published GfC13 on disclosure duties.  The controversy of the year will be the proposed reforms to the uncertain tax treatment regime, announced in March 2026.
-The list of important decisions includes ''BlueCrest Capita''l and ''Holden'' on partnership tax,'' Oscroft'' on transactions in securities, and many cases on TAARs, including ''Tower One St George Wharf Ltd''.  The pace of reform is such that the law has often been amended before the issues can be litigated.  Cases on the pre-2025 law include ''Louwman'' on the pre-2025 protected trust regime, ''Alimahomed v HMRC'' on remittances, and ''Accuro Trust'' on the pre-2020 excluded property trust rules.  In the context of treaties we have Masters on employment income, and ''Methanex Trinidad'' on treaty shopping.
+The list of important decisions includes ''BlueCrest Capita''l and ''Holden'' on partnership tax,'' Oscroft'' on transactions in securities, and many cases on TAARs, including ''Tower One St George Wharf''.  In the context of treaties we have Masters on employment income, and ''Methanex Trinidad'' on treaty shopping. The pace of reform is such that the law has often been amended before the issues have been litigated.  Last year's cases include ''Louwman'' on the pre-2025 protected trust regime, ''Alimahomed v HMRC'' on remittances, and ''Accuro Trust'' on the pre-2020 excluded property trust rules.
 ===Simplification/complification===
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 ==Withdrawal of paper edition==
-This work is now only available online.  Some readers will miss the paper edition, but online is better as it is undatable, searchable and portable. The online archive will preserve snapshots of the text at the beginning and end of the tax year.
+This work is now only available online.  Some readers will miss the paper edition, but online is better as it is updatable, searchable and portable. The online archive will preserve snapshots of the text at the beginning and end of the tax year.
 ==The future==
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 :Following the 2025 call for evidence on Personal Tax Offshore Anti-Avoidance Legislation, the government has committed to an ambitious reform agenda and intends to substantially simplify the legislation in this area.
-:HMRC will adopt a co-creation approach by engaging a small group of external experts from representative bodies, complemented by broader stakeholder engagement, to help shape the reforms. Representatives will be invited to share ideas on potential new policy and modernised legislation. While the core group will be intentionally small to maintain momentum, the government remains committed to inclusive engagement throughout this process.
+:HMRC will adopt a co-creation approach<ref>I have not seen this term before, but there is a history to it: see Ruess, Müller & Pfotenhauer,  “Opportunity or responsibility? Tracing co-creation in the European policy discourse Open Access”
-It continues to be the case that anything could happen, and pointless to speculate.  This work seeks to state the law for 2026/27.
+Anything could happen, and it is pointless to speculate.  This work seeks to state the law for 2026/27.

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−	To view this ~~Introduction~~ in pdf format, click here: [https://tfd.wiki.anarres.org/images/e/e0/FD_Introduction.pdf Introduction And What's New]	+	To view this in pdf format, click here: [https://tfd.wiki.anarres.org/images/e/e0/FD_Introduction.pdf Introduction And What's New]

	==Abolition of domicile and scope of this book==		==Abolition of domicile and scope of this book==