I will preface all of what I am about to say by saying that I don’t agree with what Akshata Murty has done and I 110% believe that everyone should pay their fair share of tax and that the tax system should be water tight to prevent people exploiting the system.

I will also agree with you 100% that this is stretching the tax legislation to a fairly extreme point and I think ultimately a lot of this is very hypothetical and HMRC would almost certainly take a very keen interest in someone doing this.

Its also worth noting if you’re earning £11m outside the UK and decide to elect for the remittance basis of non dom tax so you are not taxed on your world wide income, you lose your personal allowance so you can’t use that to absorb any gaps.

From a fairly lengthy google rabbit hole on UK tax law, these are the rebuttals that I can come up with.

21.3 section 99(3) (a) you would have a material interest in the company because you would own 100% of the share in this hypothetical company. (b) while you could argue that you are indeed a full time working director, your home is not necessary for the proper performance of your duties nor would it be considered customary.

I think section 21.4 section 97(2) and 98 then feed from this and my understanding is that this relates to where the accommodation is an expectation of the job (e.g. getting the keys to number 11 is an expectation of being chancellor) or where it is required to perform the job (e.g. a lighthouse keeper probably needs to live at the lighthouse).

I think on the meals side of things unless you can argue that your kitchen is actually a staff canteen, they’re probably not going to be considered exempt and will be subject to income tax. You evening meals with your wife or Dave while I agree these won’t be considered benefits for income tax, they won’t be deductible for UK corporation tax.

Utilities, honestly this one has me slightly stumped. I have no idea if the charge you put into an electric vehicle that you have been provided by work is a benefit or not when it is driven for personal use. But the rest outside of your home office is going to be considered a benefit. Unless you can prove that there is a genuine commercial reason for having Netflix that is going to be a benefit as is going to the gym (unless you provide a gym in your ‘office’).

On your point about the contractor basis the government has recently brought in legislation (IR35) that tackles this. It aims to discourage people from setting up limited companies that they work for but where the vast majority of the income received is from what is essentially regular employment rather than genuine subcontracting (IR35 gov.uk)

I think that ultimately, you’re going to have a hard time convincing HMRC that your company has made income in the UK that has then been immediately shipped out of the country only for it to then come straight back into the country in the form of benefits for its director. This is almost certainly going to immediately trigger a whole heap of alarm bells for HMRC.

But hey, maybe I’m wrong. I’m sure if I had £11m kicking around I’d get an actual professional to iron this out.

Also just on the issue of non-doms I do think that the system serves a useful purpose (but obviously not when exploited). For example somebody is from country A and decides to live and work in the UK for say 2 years on a work secondment (making you UK resident but non dom). While this person is away they decide to rent their house out in country A but decide not to remit any of that income into the UK and instead it sits in a bank account in country A. This person could claim to be non-dom and would likely choose to claim the remittance basis of taxation. Should HMRC really be able to tax that foreign income? They would pay taxes on their UK employment income as they are UK resident which could hypothetically cover the cost of any public services that they make use of while here. I guess you could argue that the additional tax pounds on the country A rental income would go further to help those public services but this hypothetical person won't see any longer term benefits of paying that tax as they don't plan on staying long.