New rules for resident/non-domiciled taxpayers in the United Kingdom : reflections in light of tax treaties and EC tax law

The new rules introduced in the United Kingdom for long-term resident/non-domiciled taxpayers who use the remittance basis of taxation levy an annual charge of GBP 30,000 on them. The new rules also deny the personal income tax allowances to all resident/non-domiciled taxpayers who use the remittance basis regardless of the length of their UK residence. After describing the new rules, the article analyses them from the perspective of tax treaties based on the OECD Model and from the perspective of the settled case law the European Court of Justice on the fundamental freedoms guaranteed by the EC Treaty.