I know that the Revenue doesn’t like the idea of the remittance basis but that numerous previous attempts at a review have all ended up on the too difficult pile. The comments attached to the above article demonstrate the wide range of feeling and the fact that many people simply react to the screaming headlines rather than understanding the rules.

I do not have a huge amount of guidance on Mr Darling’s view of these matters but the searching questions now asked in the 2007 tax return would suggest that HMRC is intending to apply the law strictly and to question people’s domicile status carefully rather than fundamentally change the law. We will perhaps see if anything comes out of the pre-budget report (which rumour has it is likely to be in October this year) to give us a clue.

In the meantime, anyone who believes they are non UK domiciled should perhaps be considering the strength of their case if challenged by HMRC.

This is one long running debate that is certain to be continued..

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