Reforms of the taxation of non-domiciles - CIOT comments

6 Jul 2017

As part of the process, the Scotland Office and Treasury set up a High Level Implementation Group appointing among others, John Whiting of the CIOT as a member.

As a first proactive step, the CIOT‚ s Scotland Branch conducted a survey on member‚ s views of the proposals and in particular what are the main issues that need to be addressed for successful implementation of the proposals. Members were asked to identify their three main concerns and the results (99 responses) were:

How to minimise the burdens on employers of Scottish taxpayers


How to define a Scottish taxpayer


Complexity caused by exclusion of savings income from the tax base


Interaction of income tax and benefits


PAYE coding


There were mixed responses to questions about the other taxes to be devolved. For example, most did not see the devolution of environmental taxes as having any great impact ‚ perhaps not surprisingly given the low level of tax revenue generated by them. Most respondents doubted whether the costs of implementation would justify the expected benefits of implementing the proposals (77 to 13) while some doubted the proposals to exclude investment income from the scope of the Scottish income tax powers.

In addition to the survey, the CIOT together with ICAS organised a roundtable discussion of the proposals at the Scottish Parliament on 20 September. This was attended by members of both bodies as well as members of all five political parties represented in the Scotland Parliament. The CIOT was also represented at a working group on Income Tax and PAYE on 25 October and on Charities and Gift Aid on 11 November.

Implementation is a long way off but the process of implementation has got off to the best start it could with very early consultation on the issues. Calman documents will be grouped on the CIOT website at: