Mobile Individuals: Tax Policy - Revision history

Ruth Shaw at 08:12, 8 April 2026

2026-04-08T08:12:58Z

Ruth Shaw at 10:59, 5 January 2026

2026-01-05T10:59:54Z

Ruth Shaw at 10:58, 5 January 2026

2026-01-05T10:58:35Z

Ruth Shaw at 10:52, 5 January 2026

2026-01-05T10:52:49Z

Ruth Shaw at 11:48, 17 November 2025

2025-11-17T11:48:52Z

Show changes

Ruth Shaw at 09:32, 30 September 2025

2025-09-30T09:32:20Z

Ruth Shaw at 09:20, 28 August 2025

2025-08-28T09:20:23Z

Ruth Shaw: /* Other tax competition */

2025-07-23T08:37:22Z

‎Other tax competition

Ruth Shaw: /* Tax Consultation Framework */

2025-07-23T08:36:38Z

‎Tax Consultation Framework

Ruth Shaw: /* Tax Consultation Framework */

2025-07-23T08:35:43Z

‎Tax Consultation Framework

@@ Line 140: / Line 140: @@
 So in the future there might be no shortage of corporation tax competition within the UK.</ref>
-Similar issues apply to taxation of individuals.<ref>See [[Rates of Income Tax/CGT#IT competition within UK | IT competition within UK]]</ref>  Competition in the field of new UK residents is therefore only one aspect of a wider topic.
+Similar issues apply to taxation of individuals.<ref>See [[Rates of Income Tax/CGT/CT#IT competition within UK | IT competition within UK]]</ref>  Competition in the field of new UK residents is therefore only one aspect of a wider topic.
 ===Attitudes to tax competition===

@@ Line 1: / Line 1: @@
 ''Users may [[contribute to the text]].  If you see anything that needs correcting or expanding, please click on the edit link and make the corrections.  A copy of the next edition of the book will be given to the user who makes the most edits.  User contributions are reviewed by [https://www.taxchambers.com/team/rebecca-sheldon/ Rebecca Sheldon]''
-For this chapter in pdf format click here: [https://tfd.wiki.anarres.org/images/5/5a/FD_1_Foreign_Domicile_Tax_Policy_%281%29.pdf  Chapter 1 Mobile Individuals: Tax Policy]
+For this chapter in pdf format click here: [https://tfd.wiki.anarres.org/images/0/09/FD_1_Foreign_Domicile_Tax_Policy_%282%29.pdf  Chapter 1 Mobile Individuals: Tax Policy]
 ==Scope of chapter==

@@ Line 328: / Line 328: @@
 What proportion of IHT strictly due will be properly paid on the death of non-resident LTRs, or on settlements made by non-resident LTRs?
 ===Economic benefit: FIG relief===
@@ Line 402: / Line 404: @@
 That is not comparing like with like.  FIG exemption while it lasts is more generous than a remittance basis, is uncapped, and does not incur a significant flat tax charge.  The length of the Exempt Period is only part of the picture.
-===Will the IHT regime be stable?===
+===Will the IHT LTR regime be stable?===
 Probably not.

@@ Line 323: / Line 323: @@
 (2)	The Papers did not consider IHT: in practice the imposition of IHT on trusts made prior to becoming LTR will increase the migration response, in the author’s view, very considerably.
 Given the likely migration response, it does not seem likely to the author that the reforms will bring in any additional revenue.
 What proportion of IHT strictly due will be properly paid on the death of non-resident LTRs, or on settlements made by non-resident LTRs?

@@ Line 291: / Line 291: @@
 The are some shadows in  this sunny picture.
-(1)	The problems of the remittance basis, exacerbated by the botched reforms of 2008 and 2017, will remain for a generation: it will continue to apply to pre-2025 unremitted income/gains, only partly  mitigated by the TRF.  These problems are worsened by the 2025 amendments to the definition of remittance, which the reader may think were quite unnecessary, given the transitional nature of the new rules.  After a decade or two the issue will gradually fade into insignificance.
+(1)	The problems of the remittance basis, exacerbated by the botched reforms of 2008 and 2017, will remain for a generation: it will continue to apply to pre-2025 unremitted income/gains, only partly  mitigated by the TRF.  These problems are worsened by the 2025 amendments to the definition of remittance, which the reader may think were quite unnecessary, given the transitional nature of the new rules.  After a decade or two the issue will gradually fade into insignificance. <br/>
+(2)	The individual has to compute the income/gains in order to claim FIG relief; in this respect the remittance basis was simpler, as unremitted income/gains did not have to be computed.<br/>
 (2)	The individual has to compute the income/gains in order to claim FIG relief; in this respect the remittance basis was simpler, as unremitted income/gains did not have to be computed.
-−
 (3)	The abolition of protected trusts (certainly a simplification) means that attention will need to be given to the ToA and CGT s.3 motive defences, and reliefs such as SSE, which may not have mattered for protected trusts. Simplicity is not simple to achieve.
@@ Line 344: / Line 342: @@
 If one accepts that taxation ought in principle to be progressive, which has long been a broad feature of UK taxation, then it is difficult to claim that FIG relief is fair.  The domicile Technical Note, significantly, makes only one reference to fairness:
-:The government is committed to addressing unfairness in the tax system, so that everyone who is long-term resident in the UK pays their taxes here
+:The government is committed to addressing unfairness in the tax system, so that everyone <u>who is long-term resident in the UK</u> pays their taxes here
 It is interesting to compare the 1988 Consultative Document (Residence in the UK) which proposed that the remittance basis would be abolished, and those resident here for less than seven out of 14 years (and, perhaps, also not UK domiciled) would qualify for a new “intermediate basis” of taxation.  A drawback of that proposal was that it would require disclosure of worldwide income in order to tax it at an effective rate of 2% or less.  FIG relief opts for practicality over fairness.
@@ Line 523: / Line 521: @@
 :''https://www.instituteforgovernment.org.uk/publications/overcoming-barriers-tax-reform''
 See too House of Lords Select Committee on the Constitution, “The Legislative Process: Preparing Legislation for Parliament”
-:''https://publications.parliament.uk/pa/ld201719/ldselect/ldconst/27/27.pdf''  ( 2017)
+:''https://publications.parliament.uk/pa/ld201719/ldselect/ldconst/27/27.pdf''  (2017)
 For Finance Bill procedures, see House of Commons Briefing Paper 813, “The Budget and the annual Finance Bill”
 :''https://commonslibrary.parliament.uk/research-briefings/sn04680''</ref>

@@ Line 2: / Line 2: @@
 For this chapter in pdf format click here: [https://tfd.wiki.anarres.org/images/5/5a/FD_1_Foreign_Domicile_Tax_Policy_%281%29.pdf  Chapter 1 Mobile Individuals: Tax Policy]
 ==Scope of chapter==
@@ Line 285: / Line 283: @@
 Accordingly there was no debate on the policy issues. Since the policy was supported by Labour, there was no opposition to  it.
-This is not to say that the 2017 reforms are not defensible, on the basis of fairness or otherwise, just that little reasoned debate took place in public, and probably limited debate took place in private.
+This is not to say that the 2025 reforms are not defensible, on the basis of fairness or otherwise, just that little reasoned debate took place in public, and probably limited debate took place in private.
 ===Clear and easy to operate

@@ Line 88: / Line 88: @@
 {| class="wikitable"
 |-
-! scope="col" style="width: 500px;text-align:left;"| '''Topic: Relief'''
+! scope="col" style="width: 300px;text-align:left;"| '''Topic: Relief'''
 ! scope="col" style="width: 400px;text-align:left;"| '''See para'''
 |-

@@ Line 478: / Line 478: @@
 :it is widely acknowledged that the [Immigration] Rules have become overly complex and unworkable.  They have quadrupled in length in the last ten years. They have been comprehensively criticised for being poorly drafted, including by senior judges. Their structure is confusing and numbering inconsistent. Provisions overlap with identical or near identical wording. The drafting style, often including multiple cross-references, can be impenetrable. The frequency of change fuels complexity.<ref> Law Com No 388, “Simplification of the Immigration Rules: Report” (2020) para 1.1.</ref>
-The [https://tfd.wiki.anarres.org/images/b/b8/2024_25_Edition.pdf 2024/25 edition] of this work considered how far has tax reform since 2011 complied with the Framework.<ref>See the [https://tfd.wiki.anarres.org/images/b/b8/2024_25_Edition.pdf 2024/25 edition] of this work, para 1.10.2 (Compliance with Framework).<br/>
+The [https://tfd.wiki.anarres.org/images/b/b8/2024_25_Edition.pdf 2024/25 edition] of this work considered how far has tax reform since 2011 complied with the Framework.<ref>See the [https://tfd.wiki.anarres.org/images/b/b8/2024_25_Edition.pdf 2024/25 edition] of this work, para 1.10.2 (Compliance with Framework).</ref>  I omit that now as the discussion is of historical interest only. In brief, compliance with the Framework’s tax reform timetable was patchy, except for the last part of the Tax Consultation Framework requiring post-implementation monitoring and evaluation, which was almost never done.<ref>Even where the FA 2018 required post-implementation reviews, the results were “singularly unilluminating. Most of them merely contains words to the effect of  'this legislation is new and we haven't yet seen how it will work in practice'.”  See Hubbard, Taxation Magazine, 4 April 2019.</ref>  It is easier to announce good intentions than to abide by them.  The culture of “ready, fire, aim” prevailed.
-Even where the FA 2018 required post-implementation reviews, the results were “singularly unilluminating. Most of them merely contains words to the effect of  'this legislation is new and we haven't yet seen how it will work in practice'.”  See Hubbard, Taxation Magazine, 4 April 2019.</ref>  I omit that now as the discussion is of historical interest only. In brief, compliance with the Framework’s tax reform timetable was patchy, except for the last part of the Tax Consultation Framework requiring post-implementation monitoring and evaluation, which was almost never done.<ref>Even where the FA 2018 required post-implementation reviews, the results were “singularly unilluminating. Most of them merely contains words to the effect of  'this legislation is new and we haven't yet seen how it will work in practice'.”  See Hubbard, Taxation Magazine, 4 April 2019.</ref>  It is easier to announce good intentions than to abide by them.  The culture of “ready, fire, aim” prevailed.
 ==="Tax Policy Making Principles"===