The Chartered Institute of Taxation rightly points out that a residence test on its own will not be a satisfactory replacement for the current domicile test (“Non-dom reforms require more than a residence test”, Letters, April 29).
An alternative approach might be to retain the domicile test but to abolish “domicile of origin”.
This provides an individual with his or her father’s domicile automatically at birth. Also when a domicile is abandoned (without a new one being established), the domicile of origin is revived.
This change would eliminate unexpected outcomes that give rise to public outrage.
This reform was recommended by the Law Commission in 1985 but never implemented. Maybe it should be revisited as a simple but effective reform.
London NW4, UK