Tax
Non-Doms are Vital to UK PLC - Stonehage Research
The economic benefits to the UK of non-domiciled residents amounts to at least £16 billion a year – nearly equivalent to Luxembourg’s GDP – without counting the trickle down effect, job creation and philanthropy from which the UK and the City of London as a financial centre benefits. The figure, which excludes housing and non-VAT expenditure, is based on the latest results from HM Revenue & Customs, the UK tax authority, after questioning under the Freedom of Information Act and is the conclusion of a lengthy research process by wealth manager Stonehage, to provide detail and context about UK "non-dom" residents and their contribution to the UK. It found that non-doms made £7.1 billion of tax contributions in the tax year to end April 2006 – £3.9 billion in income tax, £2.9 billion in VAT and £308 million in stamp duty. The income tax paid by non-doms per capita represents, on average, eight times as much as the national average. Stonehage said the data also shows that UK non-doms are paying more tax over time – 1,000 of the 6,000 tax payers earning over £1 million of taxable income a year were non-doms. And there has been a levelling off in the number of non-doms with the number of UK tax payers earning over £1 million rising from 6,000 to 7,000 in the tax year ended April 2007. The research follows the UK goverment's Pre-Budget Report in October which created considerable uncertainty for non-doms in the UK by proposing a number of changes to their existing remittance basis of taxation. The proposals are due in force from 6 April 2008 and draft legislation is due before the end of this year. Stonehage said the changes proposed suggest that there has been a marked negative shift in attitude by the UK government towards non-doms, which it found surprising given that a high proportion of them are skilled workers, particularly in financial services working in the City of London. Under the remittance basis of taxation non-doms are taxed on their foreign source income and gains only when they are "brought into" the UK. Historically, the remittance basis has been available for the period that a UK resident remains non-domiciled, regardless of how long that may have been. Under the new proposals, non-doms who have been resident in the UK for seven years or more will only be able to claim the remittance basis of taxation upon payment of a £30,000 annual charge. Where an individual decides not to pay the additional tax charge and accordingly, not to claim the remittance basis, he or she will be taxed on their worldwide income and gains. Individuals who claim the remittance basis of taxation will not be able to claim any of the personal income tax allowances. Although the rules are due to come into effect in April 2008, all previous years of residence count from that date. If the proposals become law, an individual who at 6 April 2008 has been resident in the UK for seven years will have to choose between paying the annual charge or forfeiting the remittance basis of taxation. In the meantime, said Stonehage, an issue of growing concern is whether non-doms will be asked to disclose details of overseas assets and associated income, in light of recent issues at HMRC with regards to the security of personal information. The Treasury, it says, is also planning to make changes to rules governing the tax treatment of non-doms who have lived in the UK for over 10 years, causing further uncertainty. Based on a sample of 34,800 non-dom cases handled by HMRC's Expatriate and Complex Personal Returns teams using data from self-assessment returns completed for the tax year ended April 2002, it also found that 23 per cent of non-doms had spent over six years in the UK – and may therefore be affected by the proposed annual fixed levy. Meanwhile, the government consultation proposals affecting non-doms who have lived in the UK for over 10 years could apply to approximately 14 per cent of the non-dom population.