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Taxation: Domicil

Volume 469: debated on Tuesday 11 December 2007

To ask the Chancellor of the Exchequer (1) how many non-domiciled individuals are estimated to have been resident in the UK for more than (a) seven, (b) 10 and (c) 17 tax years; (162005)

(2) how many requests for domicile rulings were made to the Capital Taxes Office and its successor HM Revenue and Customs Inheritance Taxes in each tax year since 1979-80; how many of these people were non-UK resident at the time of the request; and what information is available on their current residence status;

(3) how many people indicated non-domicile status in a P86 form in each tax year since 1979-80; of these how many (a) did not also file a DOM 1 form in each year, (b) are no longer resident in the UK; and (c) submitted self-assessment returns for tax year 2005-06;

(4) how many people filed DOM 1 forms with HM Revenue and Customs in each tax year since 1979-80; how many of these people are no longer resident in the UK; and how many of them submitted self-assessment returns for tax year 2005-06;

(5) what his most recent estimate is of the number of UK residents who would be eligible to be taxed under the remittance basis as a result of non-domicile status;

(6) what estimate he has made of the number of people expected to be affected in the years 2008-09 to 2011-12 by the measures announced in the pre-Budget report to amend the current rules to remove flaws and anomalies that allow individuals using the remittance basis of taxation to sidestep UK tax, where it is due on foreign income and gains and who are assumed to complete self-assessment tax returns;

(7) what estimate he has made of the amount of revenue expected to be raised as a result of the removal of income tax personal allowances from people claiming the remittance basis in each year from 2008-09 to 2011-12; and how many people are expected to be affected in each year;

(8) what estimate he has made of the amount of revenue expected to be raised as a result of changes to the residence rules so that days of arrival in and departure from the UK will count towards establishing residence in each year from 2008-09 to 2011-12; and how many people are expected to be affected by these changes in each year;

(9) what estimate he has made of the amount of revenue expected to be raised through (a) payment of the £30,000 annual charge on non-domiciles and (b) payment of UK income tax and capital gains tax on unremitted income and gains as a result of individuals choosing not to claim the remittance basis who would have claimed it in the absence of the charge in each of the years from 2008-09 to 2011-12;

(10) how much revenue is estimated to be raised as a result of measures announced in the pre-Budget report to amend the current rules to remove flaws and anomalies that allow individuals using the remittance basis of taxation to sidestep UK tax, where it is due on foreign income and gains in each year from 2008-09 to 2011-12; how many people are expected to be affected in each year; and on what assumptions these figures are based;

(11) what estimate he has made of the number of individuals who will choose (a) to pay the full £30,000 annual charge on non-domiciles and (b) not to claim the remittance basis but would have claimed it in the absence of the charge in each year from 2008-09 to 2011-12.

Information on the numbers affected by and the yield expected from the measures announced on residence and domicile at the recent PBR can be found in ‘Paying a fairer share: a consultation on residence and domicile’, published on 6 December.

No part of HMRC gives domicile rulings for inheritance tax purposes. Domicile is considered only as and when it is directly relevant in determining the scope of a charge to inheritance tax following an actual chargeable event. The requested information about residence is not available.

I regret that the information requested on forms P86 and DOM 1 is not available.

To ask the Chancellor of the Exchequer what assumptions he made in estimating the revenue raised from modernisation of residence and domicile taxation in table B4, page 164 of the pre-Budget report about (a) the number of non-domiciles who would pay the new £30,000 charge, (b) the gain from non-domiciles who choose to bring their tax affairs on-shore and (c) other factors for (i) 2009-10 and (ii) 2010-11; and if he will make a statement. (164230)

Information on the numbers affected by and the yield expected from the measures announced on residence and domicile at the recent PBR will be part of the consultation document published recently. The document includes a summary of the analysis held and answers a number of questions that have been asked in this area. A copy has been placed in the Library of the House.