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The Reverend, The English Spinster, and the Russian Prince

April 21, 2014

The title of this blog posting tells you absolutely nothing about what the post is about.

My son will be leaving university this year, entering the world of work, and his sisters will follow in the coming years. All I hope for him is that he enjoys his career as much as I have. If it happens to be one in which he earns money, and so can enjoy some of life's pleasures, all to the good; but my main wish for him, and for my daughters, is that they get fulfilment from whatever career paths they take.

I have been lucky: I still find accountancy, and taxation in particular, as enjoyable as when I started thirty years ago. Part of why this has happened is that I have retained an interest in taxation as an academic field (the astute reader will now start to see that the blog is not about a scandalous ménage a trois) and it is this interest which has helped me communicate on tax matters with my clients and colleagues for all these years.

Today it is Easter Monday, in the Lakes. The Beardsworth females are all studying this morning (an OU course, first year university exams and GCSEs in order of age) so what am I to do?

 

This morning felt like a tax day, so I have just read an excellent article on the political and other matters around the formation in 1872 of the UK's first double taxation treaty, which was with the Swiss Canton of Vaud, and its demise in 1958.

I had never heard of Vaud until this morning, but it is the French speaking canton which includes Lausanne.

 

It is on the shoreline of Lake Geneva, with Geneva being in a separate canton. Because Vaud did it, Geneva wouldn't conclude a similar agreement. Sounds like politics was just as grown up now as it is today.

 

The article is by Sunita Jogarajan, an academic at the University of Melbourne. She explains that Reverend Townshend died in London in 1868, and Miss England in Monteux in 1869. The Vaudois authorities sought to impose death duties on both their estates, arguing that they were domiciled in their canton. Their domicile was disputed, but the Vaudois authorities were insistent and sought to distrain on their properties in Vaud. The article doesn't state the outcome for these two estates, but their cases were the instigator of British Government action.

The article sets out the difficulties: protocol/procedure meant that there was delicacy with the British Government agreeing something with a Canton, rather than the Helvetian Federal Council; and there were attempts to enjoin Geneva, where many other British expats chose to live.

Impasse, until in 1870 it was learned that Vaud had struck an agreement with Russia after (an unknown) Russian Prince, whose income was millions of francs, had come to live in Vaud. That was the trigger that enabled the UK to conclude a similar deal.

Roll forward to the 1950s: the UK was no longer 'Great Britain and Ireland', as it has been in 1872; Russia no longer 'included Finland and Poland' as it did in 1870, but 'Great Britain and Northern Ireland' now wanted to conclude an agreement with 'Switzerland', which it did in 1956, and the 1872 agreement was terminated the following year (but the article goes into excellent detail on these dates, reminding me how long things have to take in politics).

The 1956 agreement lasted less than forty years: practitioners and clients affected by tax treaties should remember that 'nothing stays the same'.

The thought occurs to me as I write this, and it may not be correct, but if Scotland votes for independence later this year, as they might, then quite conceivably hundreds of thousands, if not millions, of wills will need to be re-written and a double taxation treaty be needed between Scotland and the remainder of the UK.

(These odds, which may of course reflect a small betting market/distortion by big bets, suggest that Scotland has only a 1 in 3 chance of voting yes.)

If the odds prove wrong, English lairds with castles in the HIghlands will become the vicars, spinsters and princes of 2014.

 

One Comment
  1. My interest, particularly since my retirement, is in the Rules of Hockey (field-hockey) largely of course because I was a player, umpire and coach.
    The Rules of Hockey are simplicity itself compared to the tax laws in any country (anything to do with money is made complicated because, it appears, people are inclined to lie about money – and sex, above all else) but your comment “Sounds like politics was just as grown up now as it is today” struck a chord. It is astonishing how differently apparently sane and rational people can interpret the words of the English language and then engage in pointless ‘in-fighting’ and power struggles in various committees which are supposed to be supporting the same ends.

    Many of the Rules of the game are now utterly ignored or inverted, applied in the opposite way that any reasonable reading of them should convey. I suspect many words of English were devised in order to conceal rather than to communicate clearly what was originally meant. There are some truly bizarre assertions made about the meaning of words like ‘attempt’, ‘voluntarily’, ‘legitimately ‘ and ‘interpretation’ (is it words or actions that are being interpreted by a match umpire?)

    One problem is that few people now take the time to read anything, they much prefer to listen to rumour and gossip and take what is said (or done) by peers as authoritative. Terms like ‘anal retentive’ or just ‘anal’ are used to describe those, like me, who can quote any Rule – there are only seventeen. Your declaration that you have “an interest in taxation as an academic field” amused me, because it is because I have an such an interest in the Rules of Hockey that I am most severely criticised. What business, they say, have I in making observations and suggestions for improvements, when I am no longer actually playing or umpiring the game?

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