Non-domicile Tax Status Debate

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Department: HM Treasury

Non-domicile Tax Status

Imran Hussain Excerpts
Tuesday 31st January 2023

(1 year, 4 months ago)

Commons Chamber
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Victoria Atkins Portrait Victoria Atkins
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I am very grateful to the hon. Gentleman for that thoughtful contribution. I hope he will understand that I must neither confirm nor deny that given where we are in the Budget cycle, but he makes an interesting point about the level of the remittance and his views on its impact.

Victoria Atkins Portrait Victoria Atkins
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The hon. Gentleman at the back has been very patient, so I will give way.

Imran Hussain Portrait Imran Hussain
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I am very grateful to the Minister. Thus far in this whole debate I have not heard one credible reason why we should not abolish non-dom tax status. The Minister seemed to indicate earlier that she is waiting for the right fiscal event, and then she will abolish it Is that right?

Victoria Atkins Portrait Victoria Atkins
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Again, I have to be very careful, as any Treasury Minister at the Dispatch Box six weeks before a fiscal event—a Budget—would have to be. The hon. Member will understand that there may or may not be market sensitivities in relation to tax policies ahead of the Budget, so I am not able to give any indication at this moment. What I am trying to do is to set out the facts in relation to tax take, and of course there will be a debate across the House about the whys and wherefores of that.

It is important, for us to have a reasoned debate, that we understand that non-domiciled taxpayers pay UK income tax, capital gains tax and national insurance contributions on their UK income and gains. That is money, as all taxpayers’ money is, that we can use to improve our schools, benefit patients in our hospitals and pour into infrastructure projects that will help level up across the country.

On top of that—again, the shadow Minister seems ready to dismiss this—non-doms have invested more than £6 billion in the UK into UK businesses, helping to grow the UK’s economy. That is an extraordinary amount of money: it is just under half the policing budget for England and Wales. I know that, when writing a speech, these sums may not seem very significant, but the real-life impact these figures have is very significant.

As the shadow Minister also, sadly, does not seem to have understood, we have in fact gone further in making sure non-doms pay their fair share of tax. In 2017, the Government reformed the rules to end permanent non-dom status and ensure all non-doms have to pay inheritance tax on any residential property owned in the UK, even when they own that property through a complicated structure such as an offshore trust or an offshore company. When the challenge was put to the shadow Minister by my hon. Friend the Member for Aylesbury (Rob Butler) about why a Labour Minister had not managed to do that before, we did not have an answer. Those affected by these reforms are paying more than £3 billion per year in UK income tax, capital gains tax and national insurance contributions on top of the earlier figures.

I would like to correct another mistake made, I am sure inadvertently, by the shadow Minister. We did in fact deal with non-domiciled taxpayers in the autumn statement, because the Chancellor closed a loophole to ensure that non-doms who have grown companies in the UK pay capital gains tax to the UK, bringing in an additional £830 million in revenue to support frontline public services. This announcement makes the tax system fairer and ensures that tax cannot be avoided by an individual exchanging shares in a UK close company for shares in an equivalent non-UK company as a way to re-categorise UK income or gains as foreign income or gains. That means that UK resident non-doms pay tax on gains and distributions received where value has been built up in the UK. The remittance basis is intended to provide an alternative tax treatment for foreign income and gains. It does not extend to income and gains that result from UK assets, and the Government are not willing to accept contrived arrangements that allowed clever tax planning to sidestep the tax charge that would otherwise have been due. As I mentioned a few moments ago, any analysis will be considered as part of the usual Budget process. We keep all taxes under review, as usual, and we do not comment on speculation around changes to tax policy outside fiscal events. That long-standing tradition has historically been respected by parties of all colours.

The Government will be voting against the Opposition motion, because it breaches established precedents and would prejudice the development of tax policies. I note that we have a Budget in just six weeks. I also note that we need to maintain an internationally competitive tax system that brings in talent and investment, which contributes to the growth of the economy. It is vital that we deal not just with the current economic problems we face, but also with the long-standing difficult ones that have beset us for decades. As the Chancellor outlined in his growth speech last week, we need to support enterprise so that more businesses want to locate here. Among other things, that means taking steps to reduce the tax burden overall. We are a party that believes in low taxation, and as soon as the fiscal situation allows, we want to reduce it. The Conservative vision for our economy is to unlock our national potential, and to be Europe’s most exciting, innovative and prosperous economy. We are making taxes fairer, simpler, and supportive of growth, to achieve the bright future for our country that I am sure we all want.