by freespirt | 2025-12-16 14:32:14+00:00
Thank you for taking the time to engage with the article. You raise several points worth addressing:

*On non-dom status:* You’re absolutely right that the old non-dom regime was indefensible as policy. The idea that someone could live in Mayfair for decades, contribute significantly to the UK economy and society, yet structure their affairs to avoid UK tax on worldwide income was indeed absurd. Lord Rothermere is the perfect example of the inequity. My point wasn’t to defend non-doms, but to note that their departure represents a revenue loss - which it objectively does, regardless of whether the previous regime was justifiable.

However, I’d push back on your characterisation that their only contribution was “Mayfair lunch bills and maids.” Many non-doms were significant employers, investors in UK businesses, property owners paying substantial SDLT and council tax, and contributors to UK charities and institutions. The departure of 1,800 people (50% above OBR forecasts) does represent a genuine fiscal impact beyond lunch bills.

*On CGT rates:* Here you’re on shakier ground. You say “it was tomfoolery having it at 10%” and claim this was the “lowest by far amongst industrialised countries.” That’s simply not accurate. Looking at OECD data:

- Switzerland: 0% (cantonal taxes vary but often much lower than UK) - Belgium: 0% on shares - New Zealand: 0% in most cases - Luxembourg: 0% after 6 months - Netherlands: effective rate often under 10% - Germany: 26.4% but only on recent gains

The UK’s 10% rate for BADR was competitive but hardly an outlier. And your claim that “no founders have ever” made decisions based on tax planning simply doesn’t match reality. Talk to any M&A advisor or tax accountant - timing of exits around tax changes is absolutely a consideration for founders and investors. It may not be the primary driver, but it’s certainly a factor in a multi-million pound decision.

*On asset prices explaining the CGT decline:* This is a fair point worth examining. You’re correct that CGT receipts are volatile and correlate with asset prices. However, the OBR itself attributed the shortfall to factors beyond just asset price movements - they specifically noted behavioural responses and structural changes. The 19% decline from £16.9bn to £13.7bn over two years occurred during a period when equity markets were actually relatively stable or rising (FTSE 100 up, property prices mixed but not collapsing). If it were purely asset prices, we’d expect to see similar patterns in other countries with buoyant markets - but we don’t.

*On international competition examples:* You dismiss Dubai as a “complete red herring” but that’s where the wealthy are actually going - 9,800 millionaire inflows projected. Whether you or I like it is irrelevant; it’s happening. On Portugal, yes, they’ve tightened some golden visa rules, but they remain significantly more attractive than the UK for many tax purposes. And on Ireland, I deliberately picked corporation tax because that’s the rate that matters most for business location decisions - which is precisely what we’re discussing.

*The fundamental point:* You can argue about whether individual tax changes were justified on equity grounds (and I’d agree with you on non-doms), but that’s separate from whether they’re producing the revenue forecasted. The OBR’s £7.5bn shortfall is a fact, not opinion. The 50% higher-than-forecast non-dom departures are measurable. The CGT revenue decline is in the data.

Whether these policies are morally right is one question. Whether they’re achieving their fiscal objectives is another. The evidence suggests they’re not - and that’s the Laffer curve dynamic in action, regardless of how we feel about the underlying fairness of previous regimes.

What’s your view on the broader revenue shortfall and the OBR’s structural deficit assessment?