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Time To Increase Tax Take From The Rich


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HOLA441

Think the suggestion is that the £5m (if there is such a thing)a year barrister is working out his way around the rules.

Thank you, you are correct.

One possible error in my statement was that I may have underestimated the income from barristers at the top end of this profession. It really is essential that those thinking they can beat these guys understand the level of intellect they are up against.

The guys writing the rules are on Civil service rates. Now who do you think you'd put your money on?

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HOLA442

Do you understand how money is created? (I sort of assume you do having been here a while)

Do you understand the fundamental issues facing the imbalance of trade between China and the USA with its dollar peg? Or even the issues of trade between the PIIGS and Germany in the Eurozone?

Right, well just extrapolate all that knowledge to individuals operating in an economy. Let's say you're Germany and one of your staff is Greece. How do you plan to redress the imbalance of trade that has built up over time if insufficient trading is done between you (indirectly in a complex economy of course) as evidenced by you having lots of dosh and them being rather indebted?

You have the following options:

1. You trade more with them.

2. They trade less (but that will hurt everyone).

3. Inflation is used to devalue the debts they have built up(indirectly to you because you have the money) and your savings of course.

4. They default on you.

5. Transfer payments are made from you to them to redress the balance.

Choose your poison well oh wealthy one.

Fascinating stuff.

Quite what on Earth it has to do with disincentivising legal tax avoidance activity by very high earnings has escaped me. Please help.

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HOLA443

The odds are stacked in favour of the scheme devisers; the money available means the best brains are on that side, and the onus is always on the government to write up rules that cannot be circumvented; the avoiders know the target they have to hit and are generally successful.

That's crap. The rules are devised to let the rich escape. The rich sponsor the politicians, that's how it works.

If you didn't know that I can only assume you're not rich yourself, just a crawling irritating sychophant.

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HOLA444

Your analysis is faulty, because it ignores the massive amount of avoidance happening at 40%. Obviously if you increase the take off the people not avoiding at 40% you get more money, but you're forgetting the people who are avoiding at 40%.

The idea of a flatter curve because of CGT chages is laughable; as I said in ther article there is no end of ways to avoid; close down one and like Hydra it simply grows more heads.

The only way to kill it is to stop feeding the monster, and the simplest way is to make the very wealthy look at the deal and say "y'know, what's the point? I might as well just pay it and move on".

:lol::lol::lol:

I don't think you know many wealthy people. Or if you do, you naively believe in their dinner conversation when they try to convey the image of being like Bill Gates.

They NEVER think like that. NEVER. Any wealth-management professional will tell you this.(we have lots in Geneva)

Tax avoidance is a way of life for the rich, if the tax rate was 10% they'd still try and avoid it.

For an insight into the way the wealthy think about tax, try this :

http://www.economist.com/business-finance/displaystory.cfm?story_id=6919139

Edited by gleeful_expat
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HOLA445

I'm not offended at all, we're all grownups here. Maybe it's naive and unworldly to think governments should be guided by moral principles as well as cost-benefit calculations. However, I think we have had 13+ years of cost-benefit government, and where has it got us? The country has problems of the financial spreadsheet type, but it also has serious problems in the culture of the political elite. To me they look like deeply cynical people afraid to take any sort of real action.

IF ONLY we had had such a government as you describe. Actually we''ve had idealogically driven economic incompetents who lost count.

You're right, I don't think they really try to clamp down now. What was Darling's £30k tax for non-doms if not an admission that the Government would not pursue very rich people who didn't want to pay tax? I think we have had too many years of Governments grovelling to the rich on the basis that if they were to sell up and leave, we would all be screwed. I don't believe that for one second. If some rich people were to sell up and leave, some bright young Richard Branson wannabe would just take their place. If they didn't sell up and just moved away, we could continue to tax their activities within the UK.

It was an admission that alternative arrangements would have yielded lower revenue.

Corruption breeds corruption, and sometimes you have to wade through mud to get to somewhere better. I think Britain has been extraordinarily kind to top earners for many years, ever since the 80s really. There are plenty of statistical studies showing that the poor pay a higher proportion of their income in tax than the richest 1%, and your £2m friend anecdote fits in with that. That is totally unjust, and I don't think it's particularly subjective to say that either. I agree with you that it's time to increase the tax take from the rich, but I think it's just as important for Britain to be an egalitarian society where everybody pays his fair share, including the richest 1%, and you don't get that by offering a lower marginal tax rate to people on £2m than people on £20k currently pay.

People act in accordance with self-interest; to maximise government income you have to proceed on realistic grounds. Sure, you try to pin down these guys if you like. It's like knitting jelly. While you're at it, try banning drugs successfully. See where it all gets you.

Edited by bogbrush
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HOLA446

:lol::lol::lol:

I don't think you know many wealthy people. Or if you do, you naively believe in their dinner conversation when they try to convey the image of being like Bill Gates.

They NEVER think like that. NEVER. Any wealth-management professional will tell you this.(we have lots in Geneva)

Tax avoidance is a way of life for the rich, if the tax rate was 10% they'd still try and avoid it.

For an insight into the way the wealthy think about tax, try this :

http://www.economist.com/business-finance/displaystory.cfm?story_id=6919139

What can I say, except that what I have told you is guaranteed to be correct? I can't breach confidences but it's quite honestly true.

Edited by bogbrush
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HOLA447

Thank you, you are correct.

One possible error in my statement was that I may have underestimated the income from barristers at the top end of this profession. It really is essential that those thinking they can beat these guys understand the level of intellect they are up against.

The guys writing the rules are on Civil service rates. Now who do you think you'd put your money on?

TBH the guys writing the rules are usually pretty sharp and if they do get it wrong all they need do is change the rules next year.

The more fundamental problem is that people on really big incomes usually don't need to come anywhere near the UK at all if they don't want to.

Why pay UK taxes when you can earn the same living in Switzerland, pay tax at half the rate and have a better standard of living as well?

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HOLA448

I'm rather assuming that you want to pay much less tax and you are rationalising a proposal for you to pay less tax by saying that such an action will collect more.

This is a well known but largely discredited theory.

I was trying to explain from first principles why such transfers are required in a society of trading individuals apart from any other reason - just from purely monetary principles.

Sorry if I was misreading what you were really saying.

No problems, I was only observing what happens when you give different options to people.

Simple point really; tell a guy he can pay 50% or risk a commission of 5-15% to save it all and maybe not win, or offer him to pay 25% and the latter alternative is far more likely to be taken. The former alternative is, quite simply, being taken wholesale once you go far enough up to reach meaningful sums.

It's like this Tory Inheritance Tax thing; it was always fatuous to imagine this was for the nenefit of the super-rich because they don't pay Inheritance Tax anyway; this was for the benefit of people who, for example, had a decent house in London plus some bits & pieces. Still, it's much less demanding on the mind for folk to just say they were for the Duke of Westminster types.

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HOLA449

TCP can't - and won't - get it; trends from 40% to 50% are meaningless because he doesn't know how much is being avoided at 40% (which was also the case in the above). He ignores entirely that there may be an iceberg of avoidance sat below the little bit he's seeing measured as taxed. You also ignore the potential from making the UK a preferred place to declare profits in.

No, TGP does get it........ BogBursh is making up off the top of his head, with no evidentary backup, and in the face of all historical evidence, the idea that "If only they'd drop all our tax rates to 25% we'd all stop avoiding and the govt. would earn more".

That would be fine....... if even on your ludicrous assumptions the sums added up.

Look......The 40% tax rate and above provides 66% of Income tax revenue. So, dropping it to 25% would drop fully 27.5% of all current income tax revenue (if no one extra paid up). Right ? We've lost 27.5% of total revenue from the people "actually paying" right now (or £41.25bn of the £150bn total) Now.... can we make up that £41.25bn ?

Well you are proposing taxing all the avoiders who come forward at 25%. So we've got to take 27.5% of all current revenue out of a 25% tax. So multiply that £41.25bn by 4..... £165bn of income must be being currently avoided and these guys must come forward.

That much is NOT BEING AVOIDED. Not even close to that much. The HMRC estimate is £10bn of taxes (and so £25bn of income roughly) is being avoided, total..... roughly 15% of the amount needed to make these sums work. Even assuming they are out by 100-200% and the "real" figure is 30-45% of the amount we'd need still wouldn't make it work.

And that assumes, generously, that your 25% rate prompts EVERYONE to come forward and volunteer to pay tax.

The fact is........ If I earn $100m a year....... and I can avoid that 25% tax for the cost of £10m a year in accountants fees, keeping me £15m in the black by avoiding, then I'm still going to avoid it. So thats an unrealistic assumption in any case. A 25% tax rate WILL NOT prompt EVERY avoider to come forward.

People WILL avoid tax given the opportunity....... and the fact that the fees to do so are lower than the tax saved. You really think Rupert Murdoch is going to think "25% is fair, call off the accountants. I'll pay 25%" is he b*llocks. "He's going to say, well.... is it worth it ?" and they'll reply "Carry on avoiding and you'll take home an extra £25m this year than you would if you paid up" and he's going to reply "Fine, lets keep avoiding then".

Once you factor THAT in...... that your massive tax cut will probably only cut avoidance in half, if that, rather than 100%.... well, THEN it's a HUGE loser.

On these sums....

Most Generous Scenario (HMRC is out by 200% on their estimate of hidden income, all 100% of tax avoiders come in) HMRC would lose ...... £22.5bn a year.

Generous Scenario (HMRC is out by 100% in their estimate of lost revenue, 80% of tax avoiders come in) HMRC would lose ...... £31.25bn a year.

Realistic Scenario (HMRC is out by 50% in their estimate of lost revenue, 60% of tax avoiders come in) HMRC would lose ...... £35.5bn a year.

Pessimistic Scenario (HMRC is dead on in their estimate of lost revenue, 50% of tax avoiders come in) HMRC would lose ...... £38bn a year.

Tax figures came from this article (total tax figures) and this one (amount of tax avoidance).

Sorry Bogbrush...... but even on very optimistic assumptions....... it's a MASSIVE revenue loser. And no amount of you "waving your hands in the air and claiming different" will change that.

Yours,

TGP

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HOLA4410

People act in accordance with self-interest; to maximise government income you have to proceed on realistic grounds. Sure, you try to pin down these guys if you like. It's like knitting jelly. While you're at it, try banning drugs successfully. See where it all gets you.

I suppose this is what our disagreement comes down to. You don't believe trying harder to enforce existing taxes would increase revenue, I'm saying it might so let's give it a try. Reckon it's been a good few decades since anybody had a real crack at it, let's see what can really be achieved in an age of government-backed computer-aided tax enforcement.

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HOLA4411

TBH the guys writing the rules are usually pretty sharp and if they do get it wrong all they need do is change the rules next year.

The more fundamental problem is that people on really big incomes usually don't need to come anywhere near the UK at all if they don't want to.

Why pay UK taxes when you can earn the same living in Switzerland, pay tax at half the rate and have a better standard of living as well?

And what they alter has holes in, and so it goes.

I MUST STRESS THIS IS NOT ONE OF MY MORAL/PERSONAL OPINION ARGUMENTS. THIS IS PURE PRAGMATISM.

Shoot the situation, not the messenger.

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HOLA4412

No, TGP does get it........ BogBursh is making up off the top of his head, with no evidentary backup, and in the face of all historical evidence, the idea that "If only they'd drop all our tax rates to 25% we'd all stop avoiding and the govt. would earn more".

That would be fine....... if even on your ludicrous assumptions the sums added up.

Look......The 40% tax rate and above provides 66% of Income tax revenue. So, dropping it to 25% would drop fully 27.5% of all current income tax revenue (if no one extra paid up). Right ? We've lost 27.5% of total revenue from the people "actually paying" right now (or £41.25bn of the £150bn total) Now.... can we make up that £41.25bn ?

Well you are proposing taxing all the avoiders who come forward at 25%. So we've got to take 27.5% of all current revenue out of a 25% tax. So multiply that £41.25bn by 4..... £165bn of income must be being currently avoided and these guys must come forward.

That much is NOT BEING AVOIDED. Not even close to that much. The HMRC estimate is £10bn of taxes (and so £25bn of income roughly) is being avoided, total..... roughly 15% of the amount needed to make these sums work. Even assuming they are out by 100-200% and the "real" figure is 30-45% of the amount we'd need still wouldn't make it work.

And that assumes, generously, that your 25% rate prompts EVERYONE to come forward and volunteer to pay tax.

The fact is........ If I earn $100m a year....... and I can avoid that 25% tax for the cost of £10m a year in accountants fees, keeping me £15m in the black by avoiding, then I'm still going to avoid it. So thats an unrealistic assumption in any case. A 25% tax rate WILL NOT prompt EVERY avoider to come forward.

People WILL avoid tax given the opportunity....... and the fact that the fees to do so are lower than the tax saved. You really think Rupert Murdoch is going to think "25% is fair, call off the accountants. I'll pay 25%" is he b*llocks. "He's going to say, well.... is it worth it ?" and they'll reply "Carry on avoiding and you'll take home an extra £25m this year than you would if you paid up" and he's going to reply "Fine, lets keep avoiding then".

Once you factor THAT in...... that your massive tax cut will probably only cut avoidance in half, if that, rather than 100%.... well, THEN it's a HUGE loser.

On these sums....

Most Generous Scenario (HMRC is out by 200% on their estimate of hidden income, all 100% of tax avoiders come in) HMRC would lose ...... £22.5bn a year.

Generous Scenario (HMRC is out by 100% in their estimate of lost revenue, 80% of tax avoiders come in) HMRC would lose ...... £31.25bn a year.

Realistic Scenario (HMRC is out by 50% in their estimate of lost revenue, 60% of tax avoiders come in) HMRC would lose ...... £35.5bn a year.

Pessimistic Scenario (HMRC is dead on in their estimate of lost revenue, 50% of tax avoiders come in) HMRC would lose ...... £38bn a year.

Tax figures came from this article (total tax figures) and this one (amount of tax avoidance).

Sorry Bogbrush...... but even on very optimistic assumptions....... it's a MASSIVE revenue loser. And no amount of you "waving your hands in the air and claiming different" will change that.

Yours,

TGP

You need to start reading instead of typing.

Where did I call on all income taxed at 40%? Read the original article.

Anyway, it's cool by me that they carry on as now. No skin off my nose whatsoever.

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HOLA4413

Speaking as someone who gets taxed at higher rate, but has reclaimed about 98% of his 2009-10 income tax ...

If it was an honest 40% and a fair system, I'd never have got started on tax-efficiency.

I decided to reduce my tax burden, partly because it was a lot higher than the headline rate (NI is more than Income tax for those on "standard rate"), but also due to anger over what our taxes are spent on. Ranging from keeping me priced out of a house, to sending our troops off into such a lot of illegal trade fairs for our armaments industries.

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HOLA4414

And what they alter has holes in, and so it goes.

I MUST STRESS THIS IS NOT ONE OF MY MORAL/PERSONAL OPINION ARGUMENTS. THIS IS PURE PRAGMATISM.

Shoot the situation, not the messenger.

Lol,

It just so happens that I am arguing that cutting my taxes will raise more money. This is pure pragmatism.

I haven't done any sums. I have no idea if it WILL raise revenues. But cut my taxes.....out of pragmatism.

Whatsmore (because someone just did them) I now know that WHEN YOU DO THE SUMS they show that revenue would go down, even in ludicrously optimistic scenarios, and by a very large amount (roughly 20% or so of all current IT revenue) nevertheless I must recommend OUT OF PURE PRAGMATISM you should cut my taxes in order to increase revenues.

Message Ends.

Yours,

TGP

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HOLA4415

Well, if it were moral hazard and perverse incetives we would want to avoid I would:

1. Get rid of cgt

2. Get rid of inheritance tax

as they are too easy to avoid. Only 'the little people' pay them.

But in their place I would levy a property tax (impossible to hide) and I would get rid of 'family trusts' and 'non dom' status etc. for the rich.

I don't care if they leave. I don't want them here if they are simply accumulating money at our expense. Don't even let them set foot back in the country I say.

Whilst I disagree with the principles within the property tax proposal I totally agree with where your thinking is going.

There are some things going on which I find faintly mad; banning drugs and prostitution are two which I find similar to the efforts of HMRC to create and nurture a thriving tax avoidance industry.

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HOLA4416

You need to start reading instead of typing.

Where did I call on all income taxed at 40%? Read the original article.

Anyway, it's cool by me that they carry on as now. No skin off my nose whatsoever.

Oh, I see...... you are proposing that.......

Taxes remain as they are.

40% from 40k

50% from 150k

Then they go DOWN to 25% from £300k onwards.

Lol.

Thats even MORE ludicrous than what I THOUGHT you were proposing. The people you are proposing cutting are the ones with the HIGHEST incentive to ignore your tax cut, and the LOWEST marginal costs of doing so.

The amount of people who would "come in from the cold" and stop avoiding is next to 0.

So..... You expect a man earning £100m ...... to say "I will pay £25m in tax, even though for the cost of £5m I could avoid all of it, leaving me £20m in the red".

Yet you also beleive in rational markets.

So, First......Why would a rational "revenue maximiser" reduce his yearly take home income by 20% ?

Second, in order to make this work at 25% ... you'd have to assume that the cost of avoidance was higher than 25%. Can you show me any evidence that the cost of avoiding £100m in tax is as high as £25m ?

Or the cost of avoiding £1m in tax is as high as £250k ?

Finally, how could this POSSIBLY produce as much revenue as pursuing the loopholes used by these very high incomes aggressively at 50% ? You'd only need to close loopholes equivalent to HALF those who would come in from the cold to make this MORE worthwhile, as thats next to 0..... closing very few loopholes would bring in more money.... and, incidentally, be highly politically viable.

Yours,

TGP

Edited by TGP
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HOLA4417
17
HOLA4418

Poor countries that have very low detection rates often have very severe puishments to make up for it - to act as a deterrent.

Had you considered more draconian punishment - principle based intent of course rather than based on legalistic argument.

Perhaps a couple of arms to start with and full page ads in the papers?

If people don't become more responsible and show solidarity to their fellow citizens, this is the sort of country we will end up with.

If we're only focussing on people operating within the law - which is the only thing I think is worth considering - then I don't see this as relevent.

If, for example, you figure out that you can legally write off all your time spent on HPC against income and so do because it's allowed in the statute, do you think punishment is a fair outcome? Too arbitary I suggest.

Anyway, interesting debate. As a pragmatist I know where'd I'd go; based on facts of course, I said right at the start that the numbers need grasping (but not simplistically).

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HOLA4419

You've ignored risk of failure in your "rational" argument.

Well, you can include some kind of "insurance premium" for risk of failure in the yearly cost of avoidance to cover that. Not neccessarily a formal insurance contract, but some kind of "reserve fund" equivalent.

The question would then be "Are you saying the costs of avoidance + insurance premium are higgher than 25% of income" ?

They aren't......certainly not with the uber-rich you are talking about due to their far lower marginal costs of avoidance.

The guy trying to avoid 20k down at an income of £120k, he has very high marginal costs. So maybe there you could get him to drop avoidance with a cut to 25k.

The guy trying to avoid £100m on a £400m income ? Forget it. There is no way HIS costs of doing so, including such an insurance reserve fund, comes to £100m.

Yours,

TGP

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HOLA4420

Oh, I see...... you are proposing that.......

Taxes remain as they are.

40% from 40k

50% from 150k

Then they go DOWN to 25% from £300k onwards.

Lol.

Thats even MORE ludicrous than what I THOUGHT you were proposing. The people you are proposing cutting are the ones with the HIGHEST incentive to ignore your tax cut, and the LOWEST marginal costs of doing so.

The amount of people who would "come in from the cold" and stop avoiding is next to 0.

So..... You expect a man earning £100m ...... to say "I will pay £25m in tax, even though for the cost of £5m I could avoid all of it, leaving me £20m in the red".

Yet you also beleive in rational markets.

So, First......Why would a rational "revenue maximiser" reduce his yearly take home income by 20% ?

Second, in order to make this work at 25% ... you'd have to assume that the cost of avoidance was higher than 25%. Can you show me any evidence that the cost of avoiding £100m in tax is as high as £25m ?

Or the cost of avoiding £1m in tax is as high as £250k ?

Finally, how could this POSSIBLY produce as much revenue as pursuing the loopholes used by these very high incomes aggressively at 50% ? You'd only need to close loopholes equivalent to HALF those who would come in from the cold to make this MORE worthwhile, as thats next to 0..... closing very few loopholes would bring in more money.... and, incidentally, be highly politically viable.

Yours,

TGP

What's your 'vested interest' in the bull shite you peDDle?

Edited by erranta
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HOLA4421

Well, you can include some kind of "insurance premium" for risk of failure in the yearly cost of avoidance to cover that. Not neccessarily a formal insurance contract, but some kind of "reserve fund" equivalent.

The question would then be "Are you saying the costs of avoidance + insurance premium are higgher than 25% of income" ?

They aren't......certainly not with the uber-rich you are talking about due to their far lower marginal costs of avoidance.

The guy trying to avoid 20k down at an income of £120k, he has very high marginal costs. So maybe there you could get him to drop avoidance with a cut to 25k.

The guy trying to avoid £100m on a £400m income ? Forget it. There is no way HIS costs of doing so, including such an insurance reserve fund, comes to £100m.

Yours,

TGP

It's quite right to observe that it's a sliding scale; frankly at the low end you mention it's neither here nor there and I wouldn't alter rates at that level because you won't change behaviour.

As you go through the range up to the high levels you outline it's true that his marginal cost plus risk factor are very low; you may decide that fortunately the number of people there becomes so small that you're not bothered; leave him to avoid the tax (which he surely will) because you probably cannot incentivise him to do otherwise.

In the mid-range, well there's where it may get interesting. Of course, devising tight rules increases the cost and risk of avoiding, so you probably need to do that to adjust the balance, but there's no point pretending that it's a way to stop it - certainly not in a complex economy with loads of rules.

Now if there were no allowances, tax incentives whatsoever and simply one rate, that would be another story, but I really don't have the energy.......

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HOLA4422

TBH the guys writing the rules are usually pretty sharp and if they do get it wrong all they need do is change the rules next year.

The more fundamental problem is that people on really big incomes usually don't need to come anywhere near the UK at all if they don't want to.

Why pay UK taxes when you can earn the same living in Switzerland, pay tax at half the rate and have a better standard of living as well?

There is an extremely obvious solution to this if the government had the guts to do it.

Institute a law stating that if you are registered in or do you business with a tax haven, then you cannot do business with or inside the uk. Give it a 5 year time line from being on the statute books to implementation.

The choice would be to either cut ties with tax havens or cut ties with the uk, given that we are one of the worlds top 10 economies its obvious the choice that would be made if push came to shove.

Get the americans onboard something like this and it would mean that all tax havens would close.

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HOLA4423

It's quite right to observe that it's a sliding scale; frankly at the low end you mention it's neither here nor there and I wouldn't alter rates at that level because you won't change behaviour.

As you go through the range up to the high levels you outline it's true that his marginal cost plus risk factor are very low; you may decide that fortunately the number of people there becomes so small that you're not bothered; leave him to avoid the tax (which he surely will) because you probably cannot incentivise him to do otherwise.

In the mid-range, well there's where it may get interesting. Of course, devising tight rules increases the cost and risk of avoiding, so you probably need to do that to adjust the balance, but there's no point pretending that it's a way to stop it - certainly not in a complex economy with loads of rules.

Now if there were no allowances, tax incentives whatsoever and simply one rate, that would be another story, but I really don't have the energy.......

Its called the AMT (alternative minimum tax) system that the US has and works alongside the current system. You basically have a flat tax alongside the current tax system with the flat tax set at say 30% with no exemptions whatsoever. You pay the higher of the current tax or the AMT tax.

Edited by alexw
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HOLA4424

Poor countries that have very low detection rates often have very severe puishments to make up for it - to act as a deterrent.

Had you considered more draconian punishment - principle based intent of course rather than based on legalistic argument.

Perhaps a couple of arms to start with and full page ads in the papers?

If people don't become more responsible and show solidarity to their fellow citizens, this is the sort of country we will end up with.

As opposed to what we have at the moment, which is a bureaucratic kleptocracy with no effective fiscal oversight. Theft is still theft, regardless of whether it has been institutionalized or not. Perverse incentive can operate upstream as well.

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HOLA4425

Well, if it were moral hazard and perverse incetives we would want to avoid I would:

1. Get rid of cgt

2. Get rid of inheritance tax

as they are too easy to avoid. Only 'the little people' pay them.

But in their place I would levy a property tax (impossible to hide) and I would get rid of 'family trusts' and 'non dom' status etc. for the rich.

I don't care if they leave. I don't want them here if they are simply accumulating money at our expense. Don't even let them set foot back in the country I say.

hotairmail - why, in your view, is it proper to subject a UK non-dom to UK income tax on his worldwide income? ( in other words, why should a UK non-dom pay UK income tax on income derived, say in Thailand, Mexico or whereever, when such income is never remitted to the UK? where is the fairness in that?)

And, similarly, why should a UK non dom parent not have the flexibility to settle property in trust for a child and pay income tax at the rate applicable to the child (and not 50% rate applicable to trusts).

(although, more interested in your justification to no. 1 above)

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