Comments from ACCA to HM Revenue and Customs (HMRC), February 2008.
ACCA would like to thank you for the opportunity to comment. At this stage we are making only a few preliminary comments and welcome the opportunity to discuss this issue further at meetings following next month's budget.
We welcome Dave Hartnett's letter clarifying the proposals to amend the basis of taxation of non-domiciled UK residents and their offshore trusts, amid concerns about the possible flight of capital and entrepreneurs from the UK. This has helped to identify some of the concerns expressed by our members regarding the potentially far reaching effects of the proposed legislation.
One area we would highlight, however, is that more thought needs to be given to the non-domiciliary who elect for the remittance basis on overseas income and gains, but who also have substantial UK earnings or business profits which have to be dealt with on an arising basis. It would be inequitable to deny such individuals personal allowances, capital gains tax exemptions, etc. but this appears to be what is proposed.
We have been omitted from the invitation list to meetings to date on this topic and look forward to this being remedied for the future.