This week's opinion: 5 May 2022

While ‘non dom’ remains a term of abuse rather than a statement of fact, rational discussion is difficult. But given recent events and the Labour Party proposals, it seems inevitable that this area will be looked at again. It is essential that any review looks at matters in the round and does not just concentrate on a tiny number of the super-rich. There are probably several million non-domiciled individuals currently working in the UK – I would be surprised if many readers did not have a non-dom client – and with an internationally mobile workforce it is inevitable that this will continue. Both my partner and I, for example, have family members who are undoubtedly non-dom, and I am pretty certain that they are not billionaires!

The issue is not UK-source income which, despite the impression given in parts of the media, is taxable on all UK residents; it is non-UK income not remitted to this country. I suspect that in fact the flow of funds is largely the other way – with people working in the UK sending taxed income back home. 

But where foreign income is not remitted, the question is surely how long somebody has to be in the UK before they are taxed on a worldwide basis. Even the most vociferous opponents of the current system do, I believe, accept that somebody working in the UK for a short time should not have to pay UK tax on any income arising in their home country. So where do we draw the line: one, three, five years? 

There is no obvious right or wrong answer and I have no strong views myself. But I do know that the only way we are going to get to a sensible position is to take the heat out of the argument.