The United Kingdom has historically attracted international residents with its non-domicile tax status. This system has allowed individuals whose permanent home is outside the UK to benefit from specific exemptions on foreign income and gains. These individuals, known as non-doms, may live in the UK without being fully subject to UK tax on overseas income. According to estimates, nearly 80,000 non-doms currently reside in the UK.
Under the present rules, non-doms do not pay UK tax on foreign income or gains as long as the amount remains below £2,000 annually and is not brought into the UK. If the amount exceeds this limit or is transferred to the UK, it must be reported via a Self Assessment tax return. The taxpayer can then choose either to pay tax on an arising basis or to claim the remittance basis.
The Remittance Basis Explained
The remittance basis allows non-doms to pay UK tax only on income and gains brought into the UK. While this method can lead to significant tax savings, it also has consequences. Non-doms using this basis lose their personal allowances for Income Tax and Capital Gains Tax. They are also subject to a remittance basis charge: £30,000 if they have been resident for seven of the previous nine tax years, and £60,000 if resident for twelve of the last fourteen years.
This optional regime has attracted considerable attention and criticism. Many argue that it enables wealthy individuals to avoid contributing a fair share to public finances. Critics also point to the complexity and administrative burden it places on both the taxpayer and HMRC. Determining domicile status, tracking remittances, and handling foreign income adds significant complications to tax reporting.
Increasing Calls for Reform
The remittance basis, while beneficial to some, has been seen as outdated and increasingly misaligned with modern tax principles. Other countries, such as Canada and the United States, impose tax on a residence basis, meaning all residents are taxed on their worldwide income regardless of their domicile.
There has also been growing concern over inequality within the tax system. While many UK residents are taxed on all their earnings, some non-doms with substantial foreign wealth pay little or no tax on overseas income. This discrepancy has led to calls for reform, particularly in times of fiscal pressure and growing public scrutiny.
Announced Reforms in the 2024 Spring Budget
In March 2024, Chancellor Jeremy Hunt announced a sweeping overhaul of the non-domicile tax regime. The aim is to simplify the system and align the UK more closely with other global tax jurisdictions. From April 2025, the remittance basis will be abolished. In its place, a new residency-based model will be implemented.
The Chancellor described the changes as part of a drive toward a fairer and more modern tax system. By removing the domicile element and focusing on residency, the government hopes to generate an additional £2.7 billion annually by the 2028/29 tax year. Transitional arrangements will also be introduced to ease the change for affected individuals.
Current Rules for Foreign Income and Gains
Under the current regime, foreign income and gains under £2,000 that are not remitted to the UK are not subject to tax. Once the amount exceeds £2,000 or is transferred into the country, it must be reported. Non-doms can either pay tax on this amount or use the remittance basis.
The remittance basis has traditionally appealed to wealthy individuals with significant assets held abroad. However, using it becomes more expensive over time. In addition to losing personal tax-free allowances, non-doms are liable for the remittance basis charge after being in the UK for several years.
Trusts and other financial structures often play a role in how foreign income is managed. These structures can complicate tax reporting and further highlight the discrepancies between the taxation of domiciled and non-domiciled individuals.
Motivations for Reform
The government’s motivation for abolishing the remittance basis stems from a desire for fairness and simplicity. The current system is seen as difficult to administer and unfair to ordinary taxpayers. Critics argue that it allows the wealthy to exploit loopholes and reduce their tax liability.
The move to a residency-based system means all residents will eventually be taxed similarly, regardless of their domicile. This approach aligns with international standards and eliminates the complexity associated with determining an individual’s domicile status.
Moreover, the reform is expected to enhance public confidence in the tax system. When all residents are subject to the same rules, it strengthens perceptions of equity and transparency. It may also encourage broader compliance and reduce the use of aggressive tax planning strategies.
Anticipated Impact on Current Non-Doms
The upcoming changes will significantly affect individuals who currently benefit from the remittance basis. From April 2025, they will need to adapt to a new regime that taxes worldwide income on a residence basis. This change may result in higher tax bills for many non-doms, especially those with substantial foreign income.
Some non-doms may reconsider their decision to remain in the UK, while others might restructure their affairs to comply with the new rules. Financial planning will become increasingly important, particularly for those with complex international income streams.
Reactions from the Public and Tax Professionals
Reactions to the reforms have been mixed. Advocates for tax fairness welcome the changes, viewing them as a long-overdue correction. Others are concerned about potential consequences for the UK’s attractiveness to global investors and high-net-worth individuals.
Tax professionals have highlighted the need for clear guidance from HMRC. As the transition approaches, affected individuals will need detailed information to manage their financial affairs and understand their new obligations.
International comparisons suggest that the UK is following a global trend toward taxing individuals based on residency rather than domicile. The reforms are part of a broader effort to align tax policy with modern economic and social realities.
The Bigger Picture
The shift from a domicile-based to a residence-based tax regime marks a significant policy transformation. It reflects a broader change in how governments view tax fairness and economic participation. For the UK, this could mean increased tax revenues, a simplified system, and a more level playing field for all residents.
However, there are also risks. The changes may prompt some wealthy individuals to relocate or seek alternative tax jurisdictions. The long-term impact on investment and immigration remains uncertain and will depend on how the reforms are implemented and communicated.
Introduction to the Post-2025 Landscape
From 6 April 2025, the UK will implement a major shift in the taxation of non-domiciled residents, moving from a domicile-based framework to a residence-based one. As part of this change, the remittance basis will be abolished, and all UK tax residents will be subject to tax on their worldwide income.
However, to ease the transition and maintain some of the system’s previous attractiveness, the government has introduced a new four-year foreign income and gains regime and several transitional measures. Understanding how these new rules work and who they apply to is essential for non-doms and their advisors.
Who Will Qualify for the New Four-Year Regime?
The new four-year regime is designed specifically for individuals who become UK tax residents after being non-UK tax residents for at least 10 consecutive tax years. These individuals will be granted significant relief on their foreign income and gains for the first four tax years of their UK residency.
To qualify, a person must:
- Become UK tax resident on or after 6 April 2025
- Not have been UK tax resident for any of the previous 10 tax years
If both conditions are met, the individual will be eligible for the full four-year relief period. During this time, foreign income and gains will not be subject to UK tax and can be freely brought into the UK without additional charges. However, UK-source income and gains will still be taxed in the normal way.
How the Four-Year Regime Works in Practice
Under this regime, qualifying individuals will not pay tax on any foreign income and gains during their first four years of UK residency. Additionally, they will be allowed to remit foreign income and gains to the UK without triggering a tax liability. This treatment represents a significant departure from the old remittance basis, which taxed funds only when brought into the UK and often included strict remittance tracing rules.
The new system aims to simplify compliance while still providing an incentive for individuals to relocate to the UK. It also removes the need for complex remittance calculations, offering a more straightforward approach to managing international finances during the initial years of UK residency.
Treatment of Trusts Under the New Rules
For individuals who qualify for the four-year regime, distributions received from non-resident trusts during this period will not be subject to UK tax. This treatment includes both income and capital distributions. However, this favourable treatment only applies during the four-year qualifying period. Once the individual moves into their fifth year of UK residency, they will be subject to full UK taxation on trust distributions.
Trust structures established by non-doms prior to becoming UK tax residents can remain effective, but their tax treatment will change once the individual ceases to qualify for the four-year regime. Planning should be undertaken to assess whether trust assets should be distributed during the exempt period.
Impact on Individuals Already in the UK
Individuals who were already UK tax residents before 6 April 2025 but who have not yet been resident for four tax years may still be eligible for the new regime, provided they meet the 10-year non-UK residency test. This provision allows recent arrivals to benefit from the remaining part of their four-year period.
For example, someone who became a UK tax resident in 2023–24 and had not been a UK resident in the prior 10 years will still qualify for the four-year regime through 2026–27. They will benefit from non-taxation of foreign income and gains for the remainder of the four years.
Transitioning from the Remittance Basis to the Arising Basis
For non-doms who do not qualify for the new four-year regime, the transition will be more abrupt. From 6 April 2025, they will be required to pay tax on all worldwide income and gains on an arising basis. To cushion this change, the government has introduced a one-year concession.
In the 2025–26 tax year, these individuals will only be taxed on 50% of their foreign income. This transitional relief is intended to provide time to adjust to the new rules, but it does not extend to foreign gains, which will be fully taxable. Beginning in 2026–27, full taxation will apply to all worldwide income and gains for all UK tax residents, irrespective of prior non-dom status or the number of years spent in the UK.
Rebasing of Foreign Assets
Another transitional measure allows former remittance basis users to rebase the value of their foreign assets. Individuals who held foreign assets on 5 April 2019 and who have previously claimed the remittance basis can choose to rebase those assets to their market value as of that date.
This rebasing applies only if the assets are disposed of after 6 April 2025. The benefit is that capital gains will be calculated using the rebased value, potentially reducing the tax liability upon disposal. However, individuals must ensure they have appropriate documentation to support the 2019 market valuation.
The Temporary Repatriation Facility (TRF)
One of the most practical transition tools being introduced is the Temporary Repatriation Facility. This facility allows individuals who previously used the remittance basis to bring pre-6 April 2025 foreign income and gains into the UK at a reduced tax rate.
Key features of the TRF include:
- Available only for tax years 2025–26 and 2026–27
- Applies a flat tax rate of 12% on remitted foreign income and gains
- Excludes any income and gains held within or derived from trusts
The TRF provides an opportunity to clean up offshore accounts and simplify personal finances. Individuals who may have been reluctant to remit funds due to high tax charges can now consider doing so at a much lower rate.
Inheritance Tax Reform: Future Direction
In addition to changes in income and gains taxation, the government has announced its intention to reform the application of Inheritance Tax (IHT). From April 2025, the UK aims to adopt a residence-based model for IHT rather than relying on domicile status.
While details are still pending, the proposed change could significantly alter the IHT exposure for international families. Under a residence-based system, individuals who are UK residents could be subject to IHT on their worldwide estate, regardless of their domicile.
The government may introduce thresholds, minimum residency periods, or carve-outs to prevent short-term residents from being fully liable. However, the shift will likely require those with international ties to review their estate planning strategies.
Administrative Considerations and Compliance
The abolition of the remittance basis and introduction of the four-year regime will bring changes in how individuals report income. Non-doms will need to be diligent in identifying their eligibility for the new reliefs and understanding when those reliefs expire.
The transition may also require updates to financial structures, bank accounts, and investment portfolios. Careful documentation will be necessary to support claims made under the TRF, rebasing elections, and the four-year regime.
Taxpayers are encouraged to begin planning early and consult with professionals experienced in cross-border taxation. Mistakes during the transition period could result in unintended tax liabilities and penalties.
Strategic Planning for the Future
With these sweeping changes on the horizon, affected individuals should consider taking action well before April 2025. This may involve repatriating income under the TRF, disposing of rebased assets, or completing trust distributions during the four-year window.
High-net-worth individuals and globally mobile professionals may also evaluate their residency plans. For some, the UK may remain an attractive base due to its business environment and infrastructure. For others, the new tax obligations may prompt a reassessment of their location. Proactive planning can help mitigate the effects of the new tax regime and identify opportunities within the evolving framework.
Introduction to Strategic Considerations
As the UK moves toward a residency-based tax system from April 2025, individuals who previously relied on non-domicile status to manage their tax exposure must reevaluate their financial plans. The new system eliminates the remittance basis and introduces a limited four-year window of relief for qualifying newcomers. For others, transitional measures provide temporary relief, but the long-term outlook demands serious attention.
We explored the strategic implications of the reforms, the challenges non-doms are likely to face, and the planning opportunities that remain. By understanding how to navigate the new system, individuals can mitigate risks, ensure compliance, and possibly uncover advantages within the changing landscape.
Rethinking Residency Decisions
The new rules place significant emphasis on residency status, making it a key determinant of tax liability. As all UK residents will be taxed on their worldwide income and gains, some individuals may reconsider their decision to live in the UK, especially if their global income is substantial.
Deciding whether to become or remain a UK resident will depend on a range of personal and financial factors, including business interests, family ties, access to services, and the comparative tax burden in other jurisdictions. Some may choose to spend less time in the UK to avoid becoming tax resident, while others may accept the new regime and adjust their finances accordingly.
Offshore Structures and Trusts
The treatment of non-resident trusts under the new rules is another area requiring close scrutiny. While trust distributions are exempt during the four-year FIG regime, they become fully taxable thereafter. Individuals with existing offshore structures must evaluate the long-term viability of these arrangements under a system that taxes worldwide income and gains.
Trusts created by non-doms may still provide protection from inheritance tax, but this could also change if the UK shifts to a residence-based IHT system. Trustees and beneficiaries must consider whether to restructure, wind up, or distribute trust assets during the remaining tax-efficient window.
Income Repatriation Strategies
For those eligible for the Temporary Repatriation Facility, bringing funds into the UK at a reduced 12% tax rate during the 2025–26 and 2026–27 tax years may offer a unique opportunity to clean up offshore income. However, careful analysis is needed to determine which funds qualify and how they should be remitted.
It may also be beneficial to segment accounts to clearly identify income generated before and after 6 April 2025. This practice helps manage exposure and simplifies reporting under the new rules. Taxpayers should also explore the timing of investment income, asset sales, and transfers to maximise benefits from the transitional rules.
Evaluating Rebased Assets
The rebasing of foreign assets held as of 5 April 2019 allows for capital gains to be calculated using a potentially higher base value, which could reduce future tax liabilities. However, not all assets or taxpayers may qualify, and documentation of the rebased value is essential.
Investors should consider whether to dispose of rebased assets soon after April 2025 to take advantage of lower tax burdens, especially if they expect the value to decline or anticipate future rule changes. Legal and tax advice is critical in executing these disposals correctly.
Reviewing Inheritance Tax Exposure
With the planned shift from a domicile-based to a residence-based inheritance tax regime, the impact on succession planning could be significant. If enacted, individuals who become UK tax residents may face IHT on their global estate, regardless of their permanent home.
Estate planning techniques such as lifetime gifts, trust structures, and non-UK holding companies may need to be reviewed and potentially revised. It is also important to track the number of years spent in the UK, as this could influence future IHT liability under the proposed residence-based model.
Compliance and Reporting Challenges
As the UK moves away from domicile as a tax determinant, the new rules will simplify some aspects of compliance, such as eliminating the need for remittance calculations. However, they also introduce new complexities, especially during the transitional years.
Taxpayers will need to:
- Track and report all foreign income and gains
- Monitor the duration of UK residency to determine eligibility for the four-year regime
- Maintain detailed records for rebased assets
- Clearly identify income eligible for reduced taxation under the TRF
HMRC is expected to release further guidance, but proactive steps now will help reduce errors, avoid penalties, and manage obligations more efficiently.
Tax Residency Tests and Split Year Treatment
Individuals who move in or out of the UK should pay close attention to the Statutory Residence Test and the potential for split year treatment. The outcome of these tests can influence tax exposure and eligibility for reliefs under the new system.
Careful planning of arrival and departure dates, as well as ensuring compliance with tie-breaker provisions in double tax treaties, may help avoid dual residency complications. In some cases, residency could be managed to maximise eligibility for the four-year regime or to minimise worldwide income exposure.
Role of Double Tax Treaties
Double tax treaties play an important role in determining tax liabilities under the new system. They may provide relief from double taxation, determine the country with primary taxing rights, and define tax residency under treaty terms.
As individuals become fully taxable on worldwide income in the UK, understanding treaty protections and claiming them correctly will be critical. This includes correctly disclosing overseas income and applying for relief where appropriate. Failure to do so could lead to double taxation and disputes with foreign tax authorities.
Considering Alternative Jurisdictions
Some individuals may decide that the UK’s post-2025 tax regime no longer meets their personal or financial goals. In such cases, relocating to a more tax-friendly jurisdiction could become an option. Popular destinations include countries with low or no tax on foreign income, such as Monaco, the UAE, or certain Caribbean nations.
However, the decision to relocate involves more than tax. Lifestyle, education, healthcare, and family considerations often weigh just as heavily. Additionally, departure from the UK may trigger exit tax obligations or changes in investment access and business ties.
Family Office and Advisory Roles
Family offices and wealth managers will play a crucial role in helping clients navigate the changes. Their responsibilities will extend beyond routine compliance to include strategic restructuring, tax optimisation, and cross-border planning.
Key tasks may include:
- Revising asset allocation to favour tax-efficient structures
- Assisting with timing of remittances
- Facilitating communication with trustees and international advisors
- Monitoring changes to tax treaties and UK policy
High-quality advisory support will be essential to implement solutions tailored to each individual’s needs, particularly during a period of such significant reform.
The Bigger Context: Global Tax Reform Trends
The UK’s decision to move toward a residence-based model mirrors broader global efforts to create more equitable tax systems. International bodies such as the OECD have advocated for reforms that prevent tax base erosion and profit shifting.
As countries compete for talent and investment, tax policy has become a balancing act. The UK must maintain its appeal to international professionals and investors while ensuring its tax system reflects modern economic realities. The outcome of this reform will likely influence other jurisdictions considering similar changes.
Preparing for What Comes Next
Although the reforms are scheduled for April 2025, the groundwork is already being laid. Individuals affected by these changes should begin preparing now. This involves reviewing all relevant financial structures, assessing potential liabilities, and establishing clear plans for compliance and asset management.
Ongoing engagement with trusted advisors, close monitoring of HMRC updates, and early action can ensure a smoother transition. By understanding the rules and adapting early, individuals can position themselves to thrive in the new regime while protecting their wealth and financial future.
A Turning Point for UK Taxation
The abolition of the remittance basis and the shift to a fully residence-based tax regime for foreign income, gains, and potentially inheritance tax marks a fundamental change in how the UK approaches international taxation.
These changes are not only about revenue generation or simplification but also signal a philosophical pivot in policy—placing fairness and alignment with global standards at the forefront. As we consider the broader implications, it is important to explore how these reforms will influence migration, foreign investment, tax planning, and the UK’s competitive position in the global economy.
International Comparisons and Alignment
One of the key motivations behind the reforms is international alignment. Many other developed economies already operate on a residency-based taxation system. For example, countries like Canada, Germany, and France tax residents on worldwide income, irrespective of domicile. The United States taxes citizens and residents alike, regardless of physical presence.
With the global push toward tax transparency and anti-avoidance led by institutions such as the OECD, the UK’s move helps position it as a compliant and modern jurisdiction. This realignment with international norms could strengthen the UK’s negotiating power in trade and tax treaty discussions.
Implications for International Mobility
The UK has long attracted global talent and wealth, in part due to the flexibility of its non-domicile regime. High-net-worth individuals, entrepreneurs, and skilled professionals from abroad have historically found the UK appealing because of its cultural vibrancy, business infrastructure, legal protections, and tax advantages.
The reform may cause some potential or current residents to reassess their position. While the four-year foreign income and gains regime still offers an incentive for newcomers, the removal of long-term non-dom benefits could reduce the appeal for those planning permanent or extended stays. Countries competing for these individuals may capitalize on the change by offering more favourable treatment to globally mobile individuals.
Shifts in Investment Behavior
Changes to the tax treatment of foreign income, gains, and trust structures could influence how individuals choose to invest. Previously, many non-doms would retain assets offshore to take advantage of the remittance basis. Now, they may opt to repatriate income earlier or consolidate investments in jurisdictions with favorable double tax agreements.
The introduction of the Temporary Repatriation Facility provides a brief opportunity to bring offshore income into the UK at a reduced rate. This may lead to a short-term inflow of funds. However, once the TRF ends, longer-term behavioral changes may emerge, including a potential decline in UK-based investment or philanthropy from international families.
Impact on Property and Real Estate Markets
One of the more immediate areas to watch will be the UK property market. London, in particular, has been a magnet for international buyers, many of whom are or were non-doms. With increased global taxation and the potential extension of inheritance tax to residents’ worldwide estates, some may choose to reduce or avoid UK property holdings.
This shift could slow demand in the high-end market segment or result in greater turnover as individuals divest UK assets. It could also lead to changes in ownership structures, such as holding property through entities in jurisdictions with favourable estate planning frameworks.
Business and Entrepreneurial Considerations
Non-doms have historically contributed to the UK’s entrepreneurial ecosystem. Many are founders, investors, or executives in industries like finance, tech, and creative sectors. The changing tax environment may prompt these individuals to reconsider their operational base.
However, the UK remains attractive for business due to its legal system, infrastructure, and access to global markets. Entrepreneurs who derive income primarily from UK sources may find that the changes have less impact than initially feared. For globally diversified business owners, restructuring may be necessary to ensure tax efficiency under the new rules.
Advisory and Professional Services Sector Response
The transition to a residence-based tax regime will generate increased demand for professional tax and legal advice. Advisors will be required to interpret evolving guidance, assess implications, and develop customized strategies for affected clients. This includes:
- Advising on the use and closure of offshore structures
- Navigating the Temporary Repatriation Facility
- Applying rebasing rules accurately
- Managing cross-border estate planning
Firms that can offer integrated global tax services will likely see increased demand, especially from clients with assets and interests in multiple jurisdictions.
Compliance Burdens and System Modernization
The reforms simplify some aspects of the tax system, such as eliminating the need for complex remittance tracking. However, they also impose new compliance obligations. Taxpayers will need to:
- Track worldwide income and gains
- Understand their eligibility under new regimes
- Maintain proper documentation for all elections and reliefs claimed
For HMRC, the reforms offer an opportunity to modernize tax reporting and increase transparency. Future updates to the digital tax system could streamline the process, although early-stage implementation may present challenges.
Reactions from Stakeholders and Industry Groups
Reactions from industry bodies, advisory groups, and international organisations have been mixed. Some view the reforms as a step toward greater equity in the tax system, applauding the simplification and alignment with global standards. Others have expressed concern about the potential for capital flight, reduced investment, and loss of talent.
There is also concern about how the rules will be implemented in practice. Questions remain around how HMRC will verify eligibility for the four-year regime, monitor compliance, and enforce new reporting standards. Clear guidance and efficient communication from the Treasury and HMRC will be essential to a successful transition.
Unanswered Questions and Areas for Future Policy Development
Although the broad contours of the reform have been announced, several areas still require clarification. These include:
- The exact criteria for the new residence-based inheritance tax regime
- Treatment of pre-existing trusts and offshore companies
- Potential grandfathering provisions for long-term non-doms
- Interaction with UK residency rules and international double tax treaties
Policymakers may choose to refine these aspects through secondary legislation, HMRC guidance, or further policy papers. Stakeholder consultation will be critical to ensure the rules are workable and do not produce unintended consequences.
What Comes After 2025?
The long-term success of the reforms will depend on their implementation and the UK’s broader fiscal strategy. If the system proves stable, transparent, and fair, it may strengthen the UK’s reputation as a well-regulated yet competitive destination for international residents.
Future changes may build on this foundation, potentially reforming other areas of tax such as capital gains, corporate taxation, or wealth reporting. Global trends, particularly those relating to digital taxation and wealth disclosure, could also influence UK policy.
The government’s ability to strike a balance between attracting international capital and ensuring broad-based tax compliance will shape the country’s fiscal future. With careful monitoring and periodic adjustments, the new system could pave the way for a more sustainable and equitable tax environment.
Final Considerations for Stakeholders
As the new rules approach, it is essential for affected individuals to:
- Begin planning now
- Review and update existing structures
- Engage experienced tax advisors
- Stay informed about policy updates and HMRC guidance
Tax policy may continue to evolve, but early preparation will offer the best chance of success. Understanding the reform’s impact in both financial and personal terms is key to making informed decisions.
Conclusion
The UK’s decision to abolish the remittance basis and move to a fully residence-based taxation system marks a historic transformation in its approach to taxing foreign income and gains. Scheduled to take effect from April 2025, this reform will have a profound impact on non-domiciled individuals, reshaping the financial decisions of current residents and influencing the relocation choices of international professionals, investors, and entrepreneurs.
The introduction of the four-year foreign income and gains regime provides an important incentive for new UK residents, offering temporary relief and easing the transition into the full tax net. At the same time, transitional measures such as rebasing and the Temporary Repatriation Facility aim to reduce the immediate burden on existing non-doms. These reliefs create a short window of opportunity for proactive planning, asset realignment, and income repatriation before the new rules take full effect.
Beyond individual taxpayers, the reforms are set to influence broader economic dynamics. From changes in investment behaviour and property ownership to shifts in global mobility and tax competition, the UK is redefining its appeal in an increasingly transparent and interconnected world. While the new system aligns the UK with international norms and bolsters tax fairness, it also introduces new challenges in compliance, cross-border planning, and trust management.
For stakeholders from non-doms and wealth managers to policymakers and advisors early preparation is crucial. Reviewing financial structures, understanding new obligations, and planning strategically will help mitigate risks and capitalize on the opportunities presented. Success in this new regime will depend on informed decision-making, clear guidance from HMRC, and adaptive long-term planning.
As the UK embarks on this new chapter, the goal is to create a more equitable, modern, and globally respected tax system — one that balances the need for competitiveness with the principle that all residents, regardless of origin, should contribute fairly to the country in which they live and prosper.