the times | Friday April 8 2022 9
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bought a Georgian mansion set in
12 acres in his constituency in Richmond,
North Yorkshire, when he became an
MP in 2015. They also own a £7 million
mews house in Kensington, a flat in
South Kensington and an apartment in
Santa Monica, California.
This year it was said that the couple
owned four cars: a Volkswagen Golf in
London, a Range Rover in Richmond
and a Lexus and BMW in California.
The couple met in California while
studying for MBAs at Stanford Uni-
versity, where Sunak was on a Fulbright
scholarship. Murty had studied French
and Economics at Claremont McKenna
College, also in California. They married
in 2009 after four years together, with
their wedding in Bangalore attended by1,000 guests. Sunak and Murty, who
have two daughters and a labrador with
whom they live in Downing Street, go
to spin classes as a couple.
Before Sunak became an MP, they
also invested together. In 2013, when
Murty moved to Britain, they formed
Catamaran Ventures UK, which invests
in start-ups “with the view to future
capital growth and income distributions”.
Shortly before succeeding William
Hague as the MP for Richmond, Sunak
transferred his shares to Murty. She lent
the firm £4.3 million last year after it
slipped into the red. Catamaran is also
the name of the Indian investment
vehicle chaired by Murty’s father, of
which Sunak has been a director.
Murty has separately invested incompanies, including Digme Fitness, a
boutique London fitness chain that
collapsed last month, leaving the
taxpayer with debts of £415,000. The
sums owed to HM Revenue & Customs
are understood to be for unpaid VAT
and PAYE/national insurance. Murty
was one of Digme’s directors and
owned 4.4 per cent of the company.
Sunak is wealthy, although not on the
same scale. After Stanford he joined the
Children’s Investment Fund, which
targeted businesses it thought were
badly run, before leaving for the new
investment partnership Thélème.
Non-doms are an elite relic of the
colonial era, Emma Duncan, page 28
Revelation is a danger for the chancellor
and his party, leading article, page 31Akshata Murty’s claim that she is a
non-dom because of her Indian
citizenship was labelled a “disgrace” by
a tax expert yesterday amid escalating
pressure on Rishi Sunak and his wife.
After the tax status of the chancellor’s
wife emerged on Wednesday, her
spokeswoman said it was a consequence
of India not allowing its citizens to hold
dual nationality. But experts said that
she had made a proactive decision to re-
main a non-dom, meaning she does not
have to pay UK tax on foreign earnings.
Dan Neidle, a tax lawyer at Clifford
Chance, said “citizenship is irrelevant”
to an individual’s tax status and that
Murty had made a choice to be a non-
dom. He said: “You have to tick a box on
your tax return, claiming what’s called
the remittance basis. So that’s a choice
that she made. The statements implying
it wasn’t a choice are a disgrace.”
Richard Murphy, an academic and
founder of the Tax Justice Network
campaign group, said: “I’m not chal-
lenging anything that she’s done with
regard to legality. What I’m saying is
that there was an ethical choice that she
made and she continues to make... to
say I want to be considered non-dom.”
Chris Bryant, the Labour chairman
of the Commons standards committee,
said: “This is just wrong. Non-dom
status is not automatic and the
Treasury needs to urgently clarify
this inaccurate statement.”
But it is understood that Murty
does not want to renounce the
chance to return to India. There is
no suggestion that her status is ille-
gal, and it will automatically
cease in six years, after she
has been living in Britain for
15 years. She pays £30,
per year to the government
to remain a non-dom.
The row will refocus
attention on Murty’s
wealth. Her father, NR
Narayana Murthy, is one
of India’s wealthiest men,
with a net worth of more than
£3 billion. He founded Infosys in
1981, growing the company
over 21 years as chief executive
into a consulting and IT services
giant that has a market capitali-
sation of £78 billion.
Much of Murty’s income is
likely to derive from her
0.91 per cent stake in
Infosys, which is valued at
about £700 million and
would have paid her a
dividend of about
£11.6 million last year.
Murty and Sunak own
four properties. TheyIndian non-dom claim ‘is a disgrace’
Henry Zeffman Associate Political Editor
Q&A
What is a non-dom? Someone
who is resident in the UK but
declares on their tax return
that their permanent home (or
“domicile”) for tax purposes is
overseas (David Byers,
assistant money editor,
writes). Being domiciled
overseas can be hugely
beneficial for people with
significant global wealth as it
means they don’t have to pay
tax in the UK on overseas
earnings — such as foreign
investments, rental payments,
or bank interest — as long as
they don’t bring the money
into the UK. They still pay tax
on money they earn in Britain.
The status, which is part of
common law, dates from 1799
and was introduced by
William Pitt the Younger, then
prime minister, to help
powerful British colonialists
based overseas to protect
their vast foreign earnings insugar or tobacco plantations
from British tax. There are
238,000 non-doms living in
the UK, up from 162,000 in
2001.How do you get to be a non-
dom? The most common form
of domicile is domicile of
origin — essentially, this is
where you are born or where
your parents are from.
This status is automatically
determined by your father’s
domicile when you were born
— unless your parents weren’t
married, in which case it may
be the mother’s domicile. By
that measure, Akshata Murty’s
domicile of origin is Indian.
The proportion of non-
doms from the Indian
subcontinent is rising faster
than for all other nationalities
amid an economic boom in
the region, according to the
London School of Economics.
In 2001 only 4 per cent of
non-doms were Indian
compared with 14 per cent in
2018, up from 3,200 to 22,700.
In 2001 there were only 400Chinese non-doms, up to
3,100 by 2018.Can you change your
domicile? Yes. You can be a
UK citizen and choose to be
domiciled abroad, or a foreign
citizen (like Murty) and decide
to change your domicile to
the UK. This can be done by
ticking a box on your tax
return and it is called making
a domicile of choice.
Choosing to be domiciled
somewhere does not require
you to change nationality or
relinquish your passport. It
does require you to take some
steps to demonstrate that
your natural home is now
somewhere else, in case you
are later challenged by HMRC.
Rachel de Souza, a tax
partner at the adviser RSM,
says: “You have to become
resident in the jurisdiction
where you wish to be
domiciled, and [show] the
intention of remaining there
permanently and indefinitely.”
Katharine Arthur, a partner
at Haysmacintyre, anaccountancy firm, says steps
she would advise someone to
take if they wanted to shift
their domicile would include
selling assets and property in
your previous homeland, or
relinquishing social ties, such
as membership of clubs or
societies, family ties, plus
bank accounts or
investments.
In the event of a foreign
national actively choosing to
be domiciled in the UK,
experts say HMRC is unlikely
to check exactly how many
foreign assets you’ve moved
— the main thing is that you’ve
pledged to pay tax on all of
them in the UK.Why do it? The vast majority
of foreign nationals living here
do not choose to change their
domicile to the UK, because
keeping their global wealth or
businesses outside the UK can
be a tax advantage — many
come from significantly lower
tax jurisdictions than Britain.
The LSE report said that
three in ten individuals whoearned £5 million or more
claimed non-dom status in
2018, and 22 per cent of
bankers in the top 1 per cent
of income (above £125,000)
had claimed non-dom status
at some point. British-born
non-doms who registered
domiciles abroad included the
Daily Mail owner Lord
Rothermere and the former
HSBC boss Stuart Gulliver.Are there any other catches?
Non-dom rules have tightened
in recent years. A non-dom
who has lived here for at least
seven of the previous nine tax
years must pay £30,000 per
year to the government, while
those who lived here for 12 of
the past 14 years must pay a
special charge of £60,000 per
year, which rises to £60,
per year from the 13th year.
Non-dom status is removed
altogether for those who have
lived here for 15 years. No one
has to hold a British passport
to be taxed here in full. Murty
is understood to have moved
to the UK nine years ago.Rishi Sunak met his wife
while studying at StanfordAkshata Murty, second right, the wife of Rishi Sunak, owns a £700 million stake in
the company founded by her father, NR Narayana Murthy, left. Murty and Sunak
jointly own a Georgian mansion in his constituency in Richmond, North YorkshireTIMES PHOTOGRAPHER JAMES GLOSSOP