Although this is a new scenario for us in the UK context, we are very used to it in the international context. We have lots of taxpayers who tell us that, for tax purposes, they are resident in France or wherever while appearing to have a presence in the UK, and we are very used to policing that sort of thing.
We take a risk-based approach to compliance. In other words, we assess the risk of someone misleading us, and the level of intervention that we take is based on that risk. Relevant factors include the tax differential between Scotland and the rest of the UK; in the current tax year, that differential will be a maximum of about £300, and our assessment, therefore, is that the risk of people deliberately not complying will be pretty low. Obviously, though, if that differential grew in future, we would have to reassess that risk, and we intend to do that exercise annually and share the results with the Scottish Government.
In the circumstances that you have described, we would probably have assessed the risk to have grown significantly and therefore it would be something that we would have to actively police. That is exactly the type of case that we might well decide to investigate.
It depends on the taxpayer and their level of income, and what we know about their tax behaviours generally. For example, we will keep a close eye on a high-net-worth individual who we know has actively engaged in avoidance schemes in the past. On the other hand, if we see evidence that someone appears to have moved house, we may decide that, in that particular case, an intervention is not required. We would certainly be constantly assessing risk.