Close the avoidance routes by design. Citizenship-based taxation on worldwide wealth, a deemed-disposal exit charge crystallising liability the moment someone ceases UK tax residence — not only on renouncing citizenship — an equity-stake mechanism so illiquid family businesses aren't forced into liquidation, and real-time public transparency of every valuation and relief claimed.
Current Assessment
At 95%, the financial incentive to contest valuations or leave the country is not merely high — it is the dominant financial priority for any significant estate. This claim is the specific architecture proposed to close the routes that make that possible: universal application across every asset class (property, shares, private companies, IP, crypto, art, pensions, foundations), an exit tax triggered by ceasing UK tax residence rather than only by renouncing citizenship, and a deferred-payment/equity-stake mechanism so a genuine business owner isn't forced into a fire sale.
Evidence
Three comparable exit-tax regimes already exist and trigger on residence, not citizenship: the US (IRC §877A, deemed disposal on expatriation, gains above $910,000 taxed at ordinary capital gains rates)1; France (Article 167 bis, triggers on change of tax residence after 6 of the previous 10 years resident, deferred for EU/EEA moves)2; Norway (tightened 2022, unrealised gains above NOK 3 million taxed at 37.8% on departure, deferral capped at 12 years)3. The UK's own Treasury seriously scoped a comparable 20% "settling-up charge" for the November 2025 Budget, projected to raise around £2bn a year — not adopted, but evidence the mechanism is not a fringe idea.4
Assumptions
- An exit tax raises the cost of leaving without preventing it. Norway's own experience is the evidence available on this: wealthy departures from Norway roughly doubled in the two years immediately after its 2022 tightening. The pillar's own honest framing: this recaptures revenue from those who leave anyway, it does not stop departures outright.
- Global coordination strengthens but is not required for partial function. Physical assets cannot move and registered shares are traceable regardless of international cooperation — the claim explicitly does not depend on universal participation to capture the majority of UK wealth, which is held in forms that cannot or do not need to leave the country.
- The minimum viable coalition question is genuinely unresolved. The pillar's own Gaps Register entry states this has not been resolved — flagged honestly rather than assumed away.
Cross-Pillar Relationships
| Pillar | Connection |
|---|---|
| Tax Avoidance | This claim extends that pillar's own exit-tax proposal on one specific point — the trigger (residence, not just citizenship) — built on the US precedent this page also cites. |
| Wealth Tax or Inheritance Tax? | Documents genuine change of tax residence, maintained for years and verified at death, as the primary avoidance vector under the current system — the specific route this claim's exit tax is designed to close. |
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