Polarised opinion

Views on the taxation of non-domiciles resident in the UK are polarised within the profession let alone between it and HMRC.

This became clear at the round table discussion on residence and non-domicile held by the Chartered Institute of Taxation and chaired by Andrew Hubbard on 11 December 2007.

Observers included representatives from HMRC as well as journalists and other interested parties. Names of those speaking are withheld from this report as this enabled a frank discussion to take place.

The issues

The event began with the one speaker setting out the issues. He said that it was accepted that people should pay the fair amount of tax. It is necessary to tag income to a country in order for tax to be calculated.

Different countries have different descriptions e.g. the UK has residence the US has citizenship.

He noted that UK law relating to...