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‘We have an uncertain future now, which is always a little concerning,’ says Jennings of the post-Brexit tax landscape. ‘I have seen on this occasion — much more noticeably than in 2008, when there were changes to the rules on taxation of foreign domiciliaries — people saying,“We are going to leave.” Quite a number are quite expressly saying, “We’ve had enough.”’ The thoughtful and soft spoken tax sage laments HMRC’s increasing incoherence on policy and the length of time the industry has been waiting for details of the promised changes to UK non-dom rules, now seemingly on hold since the referendum: ‘We were supposed to get [the details] well in advance of the action date in 2017 so people had time to consider their situation and plan their affairs — but these have not been produced.’ Jennings’ cool temperament surely helps. Having been at Rawlinson & Hunter for more than 30 years, he advocates a straightforward approach, emphasising clients’ desire for consistency and his abhorrence of ‘artificial’ schemes and unjustified complications. Compared to the advantages afforded to foreign wealth in Switzerland, he says even the quality of life in London is beginning to matter less to some HNWs: ‘Switzerland has recovered its place as the favourite destination,’ thanks to its forfeit basis and fixed taxliabilities at ‘quite a reasonable level’ in some of the rural cantons. The founder of STEP’s technical committee keeps up a regular dialogue between the profession and the powers that be. Can anything help to stem the non-dom drain he’s noticed? ‘It very much depends on how the new chancellor approaches his role, and quite a bit on Theresa May making it clear that those European nationals will not be affected by any immigration proposals in the future,’ he says. ‘That is certainly a message I’d want to see given.’

Simon Jennings