Tax expert John Shenton said that the proposal to count days of arrival and departure as days of residence coupled with proposed tax rule changes that will reduce the benefit of converting income into capital could lead to top professionals such as hedge fund managers coming to live here. He said that under a treaty, people are treated as non-domicile by Her Majesty’s Revenue and Customs for tax purposes provided they do not spend any more than 183 days in the UK.

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