NON DOMICILED Status of Citizens for Tax Purposes

Rob Heale made this Freedom of Information request to HM Revenue and Customs

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Response to this request is long overdue. By law, under all circumstances, HM Revenue and Customs should have responded by now (details). You can complain by requesting an internal review.

Dear HM Revenue and Customs,
Please answer the following questions under the Freedom Of Information Act about U.K. Citizens who have "Non-Domiciled Status" for tax purposes:-
1. How many Citizens of the U.K. declared themselves as having "non-domiciled status" on their Self-Assessment Tax Returns in the following Years: 2018/19; 2019/20; 2020/21; 2021/22?
2. What Taxes are charged on people of "non-domiciled status"?
3. What measures are taken by H.M.R.C. to ensure that Citizens of "non-domiciled status"
are paying the correct amounts of taxes due?
4. What Laws are relevant to the status and tax payments of people who have "non-domiciled status"?
Thanking you in anticipation.

Yours faithfully,
ROB HEALE

Team, FOI, HM Revenue and Customs

Our ref: FOI2022/17094

Dear Rob Heale,

Freedom of Information Act 2000 Acknowledgement

Thank you for your communication of 13 April.

We have allocated the above reference which you should quote if you need
to contact us.

We will arrange for a reply to be sent to you which will either comply
with our obligations under Freedom of Information Act or, if we think it's
an enquiry that we don't need to address under the terms of the Act, let
you know why. If it is the latter we will, if possible, pass it on to a
more appropriate part of the Department for answer.

While we aim to respond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.

Yours sincerely

HMRC Freedom of Information Team

Team, FOI, HM Revenue and Customs

1 Attachment

Dear Rob Heale,

We are writing in response to your request for information, received 13
April.

Yours sincerely,

HMRC Freedom of Information Team

Dear HM Revenue and Customs,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of HM Revenue and Customs's handling of my FOI request 'NON DOMICILED Status of Citizens for Tax Purposes'.

I note that you have not confirmed or denied whether the authority holds this information, and have not applied an exemption that would remove this obligation.

As you may be aware, Section 1(1) of the FOI Act (https://www.legislation.gov.uk/ukpga/200...) states that "Any person making a request for information to a public authority is entitled to be informed in writing by the public authority whether it holds information of the description specified in the request".
I would be grateful if you could clarify whether or not this information is held, or specify which exemption of the duty to confirm or deny you are applying.

I note that answers referring to the number of people with "non domiciled status" were given in a previous Freedom Of Information Question/Response. It is therefore reasonable to expect H.M.R.C. to provide an up to date list giving the number of people with this status in recent years.

It is also a matter of public interest to the Citizens of the U.K. and to U.K. Taxpayers.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/n...

Yours faithfully,

Rob Heale

Team, FOI, HM Revenue and Customs

Our ref: IR2022/19986

Dear Rob Heale,

Freedom of Information Act 2000 Acknowledgement

Thank you for your communication of 4 May.

We have allocated the above reference which you should quote if you need
to contact us.

We will arrange for a reply to be sent to you which will either comply
with our obligations under Freedom of Information Act or, if we think it's
an enquiry that we don't need to address under the terms of the Act, let
you know why. If it is the latter we will, if possible, pass it on to a
more appropriate part of the Department for answer.

While we aim to respon d to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.

Yours sincerely

HMRC Freedom of Information Team

Team, FOI, HM Revenue and Customs

1 Attachment

Dear Rob Heale,

Please find attached our review of the original response to your
information request.

Yours sincerely,

HMRC Freedom of Information Team

Dear Team, FOI,
With reference to my Freedom Of Information Act request "NON DOMICILED Status of Citizens for Tax purposes", please answer the following questions to clarify:-

1. Would it be acceptable to replace the word "citizen" or "citizens" with the words "resident" or "residents" when referring to the U.K.?

2. Do you have any further guidance as to "narrowing" down these questions to make them more specific and better value for money?

Yours sincerely,

Rob Heale

HM Revenue and Customs

Dear Rob Heale,

Thank you for your email.

The word citizen has an entirely different meaning to the word resident. A person can be a UK resident but not necessarily a UK citizen. For example, consider a UK citizen who lives and works abroad. That person holds a British passport and is therefore be a UK citizen but, as they work overseas, they would be a non-UK resident. Their residential status would dictate their tax position.

Similarly, a non-UK citizen could live in the UK and be a UK resident if they have the right to reside in this country. And if they are permitted to work, they would pay tax as a UK resident, not as a non-UK citizen.

Any citizen could live in the UK all the time and be a UK resident or only some of the time and so declare non-domicile status.

We do publish information about non-domiciled taxpayers in the UK at:
www.gov.uk/government/statistics/statist...

Table 2 of the publication contains the number of UK tax residents that declared themselves as having non-domiciled status on their SA returns in 2018-19 and 2019-20. The publication will be updated next month to include 2020-21 data.

Regards,

HMRC Freedom of Information Team

Information Rights Unit | Solicitor's Office and Legal Services
HMRC | 8th Floor | Stratford RC | 14 Westfield Avenue | London | E20 1HZ

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