Tax Journal (TJ): Before we discuss what might happen how did we get to where we are?
SD: There are lots of different answers to that question. I could start by explaining how income tax was introduced at the end of the eighteenth century to help fund the Napoleonic wars and was levied on a remittance basis; and how in the 20th century that remittance basis became restricted broadly to UK resident foreign domiciliaries; and latterly how it became even more restricted in that it can now only be accessed by foreign domiciliaries who are not deemed domiciled. A full answer along these lines would be quite lengthy! I don’t think you can wholly ignore the history as...
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Tax Journal (TJ): Before we discuss what might happen how did we get to where we are?
SD: There are lots of different answers to that question. I could start by explaining how income tax was introduced at the end of the eighteenth century to help fund the Napoleonic wars and was levied on a remittance basis; and how in the 20th century that remittance basis became restricted broadly to UK resident foreign domiciliaries; and latterly how it became even more restricted in that it can now only be accessed by foreign domiciliaries who are not deemed domiciled. A full answer along these lines would be quite lengthy! I don’t think you can wholly ignore the history as...
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