Non-domicile Tax Status

Victoria Atkins Excerpts

Tuesday 31st January 2023 Commons Chamber

[James Murray]

Thank you, Mr Deputy Speaker, for the opportunity to set out the details of the kind of long-term workforce plan that we believe the NHS needs.

The NHS is one of the great challenges we face, but we know another challenge that parents and children across the country face: the desperate need for a modern childcare system. We need a system that supports families from the end of parental leave to the end of primary school, as the shadow Education Secretary, my hon. Friend the Member for Houghton and Sunderland South (Bridget Phillipson), has set out. As the first step in this landmark shift, we would use revenue from abolishing non-dom tax status to guarantee breakfast clubs for every primary age child in England. Too many families cannot afford the clubs before school that boost children’s learning and development and help parents to go to work. Labour’s plan would save families money as well as help parents to work the jobs and hours they choose.

Our plan to abolish non-dom status, replace it with a modern system and use the money raised to strengthen the NHS, childcare and the economy should be a no-brainer. Yet the Conservatives refuse to do it. We want to know why. This is not the first time I have asked Ministers to explain their position. In the last few months of last year, I asked Treasury Ministers five times to explain why the Government have been so reluctant to abolish this outdated tax loophole. I asked Ministers five times whether the Chancellor considered abolishing non-dom tax status, whether the Prime Minister was consulted about doing so and whether, when the current Prime Minister was Chancellor, he recused himself from discussions on the matter.

Five times I asked those questions; five times the Ministers refused to answer or even acknowledge them. Instead, Ministers have been determined to defend non-dom status. I suspect we will hear some of those same defences today. If previous debates are any guide, the Minister may well repeat her line that we should be grateful to non-doms for paying £7.9 billion in UK taxes last year.

[The Financial Secretary to the Treasury (Victoria Atkins)]

On a point of order, Mr Deputy Speaker. If I am going to be quoted, I expect to be quoted correctly. The hon. Gentleman seems to use words I am not sure he quite understands—I do not know. In my speech, I am going to help him to understand some of the words he has used. But I have only ever sought to set out the facts, which we have to take into account on the issue under discussion, which is that they do pay £7.9 billion in tax. That is the context in which I have cited that figure, not in the way that he has alleged.

[Mr Deputy Speaker]

Shadow Minister, do you want to respond to that? They were your words, not mine.

--- Later in debate ---

[The Financial Secretary to the Treasury (Victoria Atkins)]

If the House will allow me, I would like to take a moment to mark the 70th anniversary of the east coast tidal surge, which saw 307 lives lost in England, including 43 people in Lincolnshire. Sutton-on-Sea in my constituency was one of the worst affected areas, and this morning constituents and Lincolnshire residents came together on the coastline to mark this terrible day in our nation’s history. Sadly, I could not be with them, but I want to place on record that my thoughts are with them on this difficult anniversary.

The Government have five priorities, as set out by the Prime Minister. First, we will halve inflation to give respite to business and reprieve to families living under the pressure of rising prices. Secondly, we will grow the economy to create better paid jobs and opportunities across the country. Thirdly, we will ensure that our national debt is falling, so that we can secure the future of public services. Fourthly, we will cut NHS waiting lists, so that people can get the care they need more quickly. Fifthly, we will pass new laws to stop small boats. To reflect the people’s priorities, three of our priorities are economic. They are a plan for a bright future where our economy is growing faster and where people across the country have opportunities for good jobs and for their pay to go further.

The autumn statement laid out our plan to achieve that future and, despite the difficult fiscal decisions we had to make, re-emphasised our support for the most vulnerable. Having helped households throughout the pandemic, we have set up new schemes to help people and businesses with rising energy bills, and we have taken targeted action on the cost of living. We have raised pensions, benefits and the national living wage to help those who might otherwise have been left behind. Those who ask where the burden falls in paying for that support should look at the measures in the autumn statement, which, as a whole, show that we have asked wealthier people to pay more. We have asked those with the broadest shoulders to carry the heaviest burden.

Today is not only the deadline for self-assessments, but, interestingly, the third anniversary of the Conservatives keeping our promise to the British people by honouring the result of the referendum and leaving the European Union. It is therefore ironic that Labour has chosen to table this type of motion today, because it was a parliamentary device that the Leader of the Opposition fell on when he was the shadow Brexit Minister and self-identified as a Corbynite. Labour used this sort of motion to try to block Brexit, but it did not work then and it will not work now to stop the Government’s responsible handling of the economy.

The flaws in the motion are fundamental, because long-standing and crucial conventions exist that Ministers should be able to receive free and frank advice from officials. In developing policy, Ministers must have a safe space to be advised by officials. That process should not play out in public, especially given that Treasury Ministers are often dealing with issues that are highly market sensitive. Those conventions apply to Governments of all political colours. If we were to make changes to any aspect of the tax system, the right and proper place to publish related costings and assessments is at the relevant fiscal event.

Having dealt with the motion’s flawed framework, I will say that we understand the legitimate concerns of people across the country. The country has a strong instinct for fairness, and we want all people to pay their fair share of tax. As the Minister responsible for the tax system, I feel that keenly, because I know that many people across the country are under pressure at the same time as we need to fund our public services properly.

[Matt Western]

At its heart, the motion is about laying before the House the evidence and analysis undertaken by the Treasury. On the point about fairness, I am sure the British public will want to hear the answer to my simple question about the 28,000 people who are non-domiciled in this country. What is the average length of time that they have been in this country? What is the longest and what is the shortest?

[Victoria Atkins]

I am genuinely grateful to the hon. Gentleman, because that helps me to set out the progress that has been made in that area in the last decade. Non-domicile tax contributions rightly play an important part in funding our public services. Non-doms pay UK tax on their UK income and gains, and they pay UK tax on foreign income and gains when those amounts are brought into the UK.

I know the hon. Member for Ealing North (James Murray) dismisses £7.9 billion out of hand, as though it is somehow not relevant, but I set out these facts precisely because that is a very large sum of money and it helps to fund public services. It is right, in having a reasoned debate about these measures, that we adhere to the facts.

[Jamie Stone (Caithness, Sutherland and Easter Ross) (LD)]

I have a rather technical question about the remittance basis charge. Would His Majesty’s Government consider raising the lower rate from £30,000 to £60,000 and perhaps the upper rate from £60,000 to £90,000? It would make better the balance between taking in revenue and the non-doms paying their share. Furthermore, following on from that, would they index link the charges to inflation in following years?

[Victoria Atkins]

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.

[Imran Hussain (Bradford East) (Lab)]

rose—

[Victoria Atkins]

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

[Imran Hussain]

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]

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.

[Several hon. Members rose—]