Introduction - Revision history

Ruth Shaw at 13:27, 10 April 2026

2026-04-10T13:27:13Z

Ruth Shaw at 13:21, 10 April 2026

2026-04-10T13:21:38Z

Ruth Shaw at 13:16, 10 April 2026

2026-04-10T13:16:57Z

Ruth Shaw at 09:55, 27 January 2026

2026-01-27T09:55:49Z

Ruth Shaw at 09:52, 27 January 2026

2026-01-27T09:52:45Z

Ruth Shaw at 10:04, 8 December 2025

2025-12-08T10:04:16Z

Ruth Shaw: /* Abolition of domicile and scope of this book */

2025-12-08T09:37:17Z

‎Abolition of domicile and scope of this book

Ruth Shaw at 09:36, 8 December 2025

2025-12-08T09:36:33Z

Ruth Shaw at 13:09, 6 November 2025

2025-11-06T13:09:11Z

Ruth Shaw at 10:42, 22 September 2025

2025-09-22T10:42:40Z

← Older revision		Revision as of 13:27, 10 April 2026
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−	To view this Introduction in pdf format, click here: [~~https://tfd.wiki.anarres.org/images/6/6d/FD_Introduction_%281%29.~~pdf Introduction And What's New]	+	To view this Introduction in pdf format, click here: [pdf to follow Introduction And What's New]

	==Abolition of domicile and scope of this book==		==Abolition of domicile and scope of this book==

@@ Line 52: / Line 52: @@
 :My classmates were some of the best private law students in France.  This was a question to which they knew the answer.  One of them explained that article 2 provides for the nonretroactivity of the law.  Mme Gobert looked at the student without smiling.  Then she repeated the question.  ''L’article 2 du Code civil, qu’est-ce qu’il dit?'' A different student mentioned Paul Roubier’s suggestion that a new law may be applied to ''les situations juridique en cours''.  Again she repeated the question.  ''L’article 2 du Code civil, qu’est-ce qu’il dit?''   Another student tried, and then another, each new voice attempting yet a more refined statement of the concepts involved. After each comment she responded in the same way.  It was my first French law class, so I did not know what to think.  It seemed like a Zen-like version of the Socratic method.  The French students were terrified.  This was material they thought they knew, and yet they could not guess what was on her mind.  Finally, one of the students had the presence of mind simply to read the code provision aloud.  Mme Gobert’s eyes lit up.  ''Mais bien sûr!'' she responded ''C’est ça qu’il dit!''
-==The year 2025/26 in review, and the future==
+==The year 2025/26 in review==
 The FA 2026 has changes to the FA 2025 reforms.  It has enacted the IHT business property reform, which takes effect in 2026/07, and the IHT pension reform, though that does not take effect until 2027.
@@ Line 113: / Line 113: @@
 : We will further complicate the UK tax system so that large companies can no longer find loopholes.<ref> Official Monster Raving Loony Party Manifesto 2017
 :<i>https://www.loonyparty.com/2017-general-election-manicfesto</i>></ref>
 ==Withdrawal of paper edition==
@@ Line 122: / Line 120: @@
 ==The future==
-There is also a review into the settlement code, transfer of asset code and s.86/s.87 TCGA.<ref>''https://www.gov.uk/government/calls-for-evidence/personal-tax-offshore-anti-avoidance-legislation/personal-tax-offshore-anti-avoidance-legislation''</ref>  According to OOTLAR 2025:<ref>''https://www.gov.uk/government/publications/budget-2025-overview-of-tax-legislation-and-rates-ootlar/budget-2025-overview-of-tax-legislation-and-rates-ootlar''</ref>
+There is a review into the settlement code, transfer of asset code and s.86/s.87 TCGA.<ref>''https://www.gov.uk/government/calls-for-evidence/personal-tax-offshore-anti-avoidance-legislation/personal-tax-offshore-anti-avoidance-legislation''</ref>  According to OOTLAR 2025:<ref>''https://www.gov.uk/government/publications/budget-2025-overview-of-tax-legislation-and-rates-ootlar/budget-2025-overview-of-tax-legislation-and-rates-ootlar''</ref>
 :Following the 2025 call for evidence on Personal Tax Offshore Anti-Avoidance Legislation, the government has committed to an ambitious reform agenda and intends to substantially simplify the legislation in this area.
@@ Line 182: / Line 180: @@
 |}
-This book was called <i>Taxation of Foreign Domiciliaries</i> for 9 editions; it changed to <i>Taxation of Non-Residents and Foreign Domiciliaries</i> from the 10<sup>th</sup> to the 23<sup>rd</sup> edition and to ''Kessler on Private Client Taxation'' from the 24th edition.<ref>The text of [https://privateclienttax.co.uk/index.php/Archive_editions earlier editions] is available on ''https://www.privateclienttax.co.uk'' </ref>
+This book was called <i>Taxation of Foreign Domiciliaries</i> for 9 editions; it changed to <i>Taxation of Non-Residents and Foreign Domiciliaries</i> from the 10<sup>th</sup> to the 23<sup>rd</sup> edition and to ''Kessler on Private Client Taxation'' from the 24th edition.<ref>The text of earlier editions is available on [https://privateclienttax.co.uk/index.php/Archive_editions earlier editions] is available on ''https://www.privateclienttax.co.uk'' </ref>
 == Footnotes==
 <references/>

@@ Line 3: / Line 3: @@
 ==Abolition of domicile and scope of this book==
 is a year that will be remembered in tax history.  It announced a set of reforms:
@@ Line 15: / Line 17: @@
 One might summarise this package as the abolition of domicile as a tax concept, or the abolition of non-dom tax reliefs;<ref>See [[Appendix 8 Domicile#Domicile: Introduction | Domicile: Introduction]]</ref> though as usual, the short label does not fully describe the details of the reforms.
-This is the most important change in UK taxation since the introduction of CGT/CT in 1965, VAT in 1973, and CTT in 1974, and very few readers will have firsthand memory of any of those.  So it is the biggest change in our working lifetime. It will take some years to work out its consequences.
+This is the most important change in UK taxation since the introduction of CGT/CT in 1965, VAT in 1973, and CTT in 1974, ... It will take some years to work out its consequences.
-−
-Territorial rules (now based on residence, situs and source) are best addressed as part of a general discussion: in taxation, as in life, everything is connected.  Even a preliminary sketch needs more time than is available in the month between the publication of the finance bill in its final form, and the start of the tax year when this book is published; the discussion of the new law will go online over the course of the year.
-The new title of this work reflects this change and this approach.
+The reader will find the results of the first year’s work on the topic, though there is no doubt much more to be thought about, and the FA 2026 (in part retrospective to 2025) adds to the task.
 ==Co-authorship==
@@ Line 52: / Line 52: @@
 :My classmates were some of the best private law students in France.  This was a question to which they knew the answer.  One of them explained that article 2 provides for the nonretroactivity of the law.  Mme Gobert looked at the student without smiling.  Then she repeated the question.  ''L’article 2 du Code civil, qu’est-ce qu’il dit?'' A different student mentioned Paul Roubier’s suggestion that a new law may be applied to ''les situations juridique en cours''.  Again she repeated the question.  ''L’article 2 du Code civil, qu’est-ce qu’il dit?''   Another student tried, and then another, each new voice attempting yet a more refined statement of the concepts involved. After each comment she responded in the same way.  It was my first French law class, so I did not know what to think.  It seemed like a Zen-like version of the Socratic method.  The French students were terrified.  This was material they thought they knew, and yet they could not guess what was on her mind.  Finally, one of the students had the presence of mind simply to read the code provision aloud.  Mme Gobert’s eyes lit up.  ''Mais bien sûr!'' she responded ''C’est ça qu’il dit!''
-==The year 2023/24 in review, and the future==
+==The year 2025/26 in review, and the future==
-Delay in the FTT continues to be an issue.  In 2023 the Judicial Conduct Investigations Office said:
+The FA 2026 has changes to the FA 2025 reforms.  It has enacted the IHT business property reform, which takes effect in 2026/07, and the IHT pension reform, though that does not take effect until 2027.
-−
-:A nominated judge found that Mr Justice Sweeting had not issued a judgment in a timely manner and failed to immediately recognise the consequences of his actions. The judgment was not issued until 14 months after the initial hearing.
+HMRC have published GfC13 on disclosure duties.  The controversy of the year will be the proposed reforms to the uncertain tax treatment regime, announced in March 2026.
-:Mr Justice Sweeting apologised and acknowledged that the judgment should have been completed earlier. In mitigation he cited his busy sitting schedule and personal matters.
-:The lord chief justice and the lord chancellor took into consideration the mitigating circumstances in this case and agreed to issue Mr Justice Sweeting with formal advice.
+The list of important decisions includes ''BlueCrest Capita''l and ''Holden'' on partnership tax,'' Oscroft'' on transactions in securities, and many cases on TAARs, including ''Tower One St George Wharf Ltd''.  The pace of reform is such that the law has often been amended before the issues can be litigated.  Cases on the pre-2025 law include ''Louwman'' on the pre-2025 protected trust regime, ''Alimahomed v HMRC'' on remittances, and ''Accuro Trust'' on the pre-2020 excluded property trust rules.  In the context of treaties we have Masters on employment income, and ''Methanex Trinidad'' on treaty shopping.
-−
-The reader may think the JCIO is absolutely right.  But the message has not reached the FTT.  I have not done a full survey - though someone should - but note that in 2025, Judge Geraint Williams brought out ''two'' decisions more than ''eighteen'' months after the hearings,<ref>''Lloyds Asset Leasing Ltd v HMRC'' [2025] UKFTT 57 (TC) decision 20 Jan 2025, hearing dates 5-26 May 2023; ''HMRC v Asset House Piccadilly Ltd'' decision 12 February 2025, hearing dates 12-16 June 2023.</ref> without any adverse comment that I have noticed.  If the problem is acknowledged, the solution seems attainable.  There should be a target date for judgements (from 3 weeks for simple cases to 6 weeks for the most complex) and scheduling of hearings which allows judges to achieve it; and if there have to be years of delay, which of course there should not be, it would be better to defer the hearing than to extend the period between hearing and judgment.
 ===Simplification/complification===
@@ Line 94: / Line 92: @@
 |-
 | 2018  || 196 || 2025 || 296
 |}
@@ Line 116: / Line 116: @@
 Furnished holiday letting relief has gone.  This will be a simplification, as is the abolition of the remittance basis.
-==Online v paper edition==s
+==Withdrawal of paper edition==
-The online version of this work aims to cover some subsequent developments, and is therefore superior to the paper version, though both, at least for now, remain available for the reader.
+This work is now only available online.  Some readers will miss the paper edition, but online is better as it is undatable, searchable and portable. The online archive will preserve snapshots of the text at the beginning and end of the tax year.
 ==The future==
@@ Line 127: / Line 127: @@
 :HMRC will adopt a co-creation approach by engaging a small group of external experts from representative bodies, complemented by broader stakeholder engagement, to help shape the reforms. Representatives will be invited to share ideas on potential new policy and modernised legislation. While the core group will be intentionally small to maintain momentum, the government remains committed to inclusive engagement throughout this process.
-It continues to be the case that anything could happen, and at this stage it is pointless to speculate.
+It continues to be the case that anything could happen, and pointless to speculate.  This work seeks to state the law for 2026/27.
 {|
@@ Line 157: / Line 148: @@
 In particular, you may instruct the author to advise.  I enjoy writing, but spend most of my time giving independent specialist professional advice in private client matters, especially areas covered in this work. For further details see'' https://www.kessler.co.uk https://www.kessler.co.uk''
 ===Disclaimer===

← Older revision		Revision as of 09:55, 27 January 2026
Line 1:		Line 1:

−	To view this Introduction in pdf format, click here: [https://tfd.wiki.anarres.org/images/2/2b/FD_Introduction_%~~282~~%29.pdf Introduction And What's New]	+	To view this Introduction in pdf format, click here: [https://tfd.wiki.anarres.org/images/6/6d/FD_Introduction_%281%29.pdf Introduction And What's New]

	==Abolition of domicile and scope of this book==		==Abolition of domicile and scope of this book==

@@ Line 54: / Line 54: @@
 ==The year 2023/24 in review, and the future==
 Delay in the FTT continues to be an issue.  In 2023 the Judicial Conduct Investigations Office said:
@@ Line 100: / Line 98: @@
 The OTS estimated HMRC guidance at 90,000 pages in 2018;<ref>OTS, “Guidance for taxpayers: a vision for the future” (2018) para 1.21.  These pages have assuredly not been printed or counted.  Quantification raises methodological issues which deserve a short essay to itself.  We have reached the stage where the amount of HMRC guidance is impossible to quantify: the words are uncountable.  Within the limits of guesswork, and assuming 500 words per page (single spacing), the figure of 90,000 pages seems to me to be on the low side.  There are 150 HMRC Manuals, just for a start.
-Perhaps the focus of enquiry should be whether HMRC guidance is too short, because 90,000 pages would not be sufficient to do justice to the topic. The legislation, measured by pages of the Orange & Yellow tax handbooks, can be counted and amounts to 23,374 pages in 2025/26 (that does not include DTAs, which would be another 3,000 pages).  The Tax Cases reports, which began in 1875, and ceased publishing in 2014, reached 82 volumes and did not cover VAT.</ref> whatever the true figure, it will have grown considerably since then.  This guidance was “not comprehensive” - something of an understatement; but according to the OTS “real life cannot be reduced to a neat description in a few (!) pages of writing”.<ref>Para 1.24.</ref>
+Perhaps the focus of enquiry should be whether HMRC guidance is too short, because 90,000 pages would not be sufficient to do justice to the topic. The legislation, measured by pages of the Orange & Yellow tax handbooks, can be counted and amounts to 23,374 pages in 2025/26 (that does not include DTAs, which would be another 3,000 pages).  The Tax Cases reports, which began in 1875, and ceased publishing in 2014, reached 82 volumes and did not cover VAT.</ref> however the figure is calculated, it will have grown considerably since then.  This guidance was “not comprehensive” - something of an understatement; but according to the OTS “real life cannot be reduced to a neat description in a few (!) pages of writing”.<ref>Para 1.24.</ref>
 It is easier to ''talk'' of simplification.  In the ill-fated “mini” budget of October 2022:
@@ Line 117: / Line 115: @@
 Furnished holiday letting relief has gone.  This will be a simplification, as is the abolition of the remittance basis.
 ==The future==
@@ Line 135: / Line 137: @@
 Comments from my readers and clients continue to be of the greatest value and interest.  I am very grateful to all who commented, and in particular to John Barnett and Sam Dewes (who commented on a variety of topics), and Mark Pearce (cryptoassets).  In order not to be defeated by the size of this work, readers' help is needed more than ever.  If anyone would like to offer to write or revise a section - or chapter - of this book please get in touch.
-The pleasure in writing this book consists in the interest of the questions which it raises, and the success which it may have achieved in answering them. On the basis of what is known at 1 April 2025, the printed book seeks to state the law for 2025/26.  The online version aims to cover some subsequent developments.
+The pleasure in writing this book consists in the interest of the questions which it raises, and the success which it may have achieved in answering them. On the basis of what is known at 1 April 2025, the printed book seeks to state the law for 2025/26.
 {|

← Older revision		Revision as of 10:04, 8 December 2025
Line 1:		Line 1:

−	To view this Introduction in pdf format, click here: [https://tfd.wiki.anarres.org/images/6/6d/FD_Introduction_%~~281~~%29.pdf Introduction And What's New]	+	To view this Introduction in pdf format, click here: [https://tfd.wiki.anarres.org/images/2/2b/FD_Introduction_%282%29.pdf Introduction And What's New]

	==Abolition of domicile and scope of this book==		==Abolition of domicile and scope of this book==

@@ Line 13: / Line 13: @@
 :(b)	Transitional rules include the Temporary Remittance Facility, 2025 rebasing, and a new definition of remittance (for pre-2025 unremitted income)
-One might summarise this package as the abolition of domicile as a tax concept, or the abolition of non-dom tax reliefs;<ref>see [[Appendix 8 Domicile#Domicile: Introduction | Domicile: Introduction]]</ref> though as usual, the short label does not fully describe the details of the reforms.
+One might summarise this package as the abolition of domicile as a tax concept, or the abolition of non-dom tax reliefs;<ref>See [[Appendix 8 Domicile#Domicile: Introduction | Domicile: Introduction]]</ref> though as usual, the short label does not fully describe the details of the reforms.
 This is the most important change in UK taxation since the introduction of CGT/CT in 1965, VAT in 1973, and CTT in 1974, and very few readers will have firsthand memory of any of those.  So it is the biggest change in our working lifetime. It will take some years to work out its consequences.

@@ Line 120: / Line 120: @@
 ==The future==
-The 2024 budget announced two more radical reforms from 2026/27:
+There is also a review into the settlement code, transfer of asset code and s.86/s.87 TCGA.<ref>''https://www.gov.uk/government/calls-for-evidence/personal-tax-offshore-anti-avoidance-legislation/personal-tax-offshore-anti-avoidance-legislation''</ref>  According to OOTLAR 2025:<ref>''https://www.gov.uk/government/publications/budget-2025-overview-of-tax-legislation-and-rates-ootlar/budget-2025-overview-of-tax-legislation-and-rates-ootlar''</ref>
-(1)	Abolition of 100% Business/Agricultural property relief<br/>
+:Following the 2025 call for evidence on Personal Tax Offshore Anti-Avoidance Legislation, the government has committed to an ambitious reform agenda and intends to substantially simplify the legislation in this area.
-(2)	Pension IHT reform
+:HMRC will adopt a co-creation approach by engaging a small group of external experts from representative bodies, complemented by broader stakeholder engagement, to help shape the reforms. Representatives will be invited to share ideas on potential new policy and modernised legislation. While the core group will be intentionally small to maintain momentum, the government remains committed to inclusive engagement throughout this process.
-There is also a review into the settlement code, transfer of asset code and s.86/s.87 TCGA, starting with a call for evidence.<ref>''https://www.gov.uk/government/calls-for-evidence/personal-tax-offshore-anti-avoidance-legislation/personal-tax-offshore-anti-avoidance-legislation''</ref>   Anything could happen, and at this stage it is pointless to speculate.
+It continues to be the case that anything could happen, and at this stage it is pointless to speculate.
 We face a continued period of change and uncertainty, in politics, economics, law and taxation, and will continue to live in fiscally exciting times.

@@ Line 62: / Line 62: @@
 :The lord chief justice and the lord chancellor took into consideration the mitigating circumstances in this case and agreed to issue Mr Justice Sweeting with formal advice.
-The reader may think the JCIO is absolutely right.  However the message has not reached the FTT.  I have not done a full survey - though someone should - but note that in 2025, Judge Geraint Williams brought out two decisions more than eighteen months after the hearings,<ref>''Lloyds Asset Leasing Ltd v HMRC'' [2025] UKFTT 57 (TC) decision 20 Jan 2025, hearing dates 5-26 May 2023; ''HMRC v Asset House Piccadilly Ltd'' decision 12 February 2025, hearing dates 12-16 June 2023.</ref> without any adverse comment that I have noticed.  If the problem is acknowledged, the solution seems attainable.  There should be a target date for judgements (from 3 weeks for simple cases to 6 weeks for the most complex) and scheduling of hearings which allows judges to achieve it; and if there have to be years of delay, which of course there should not be, it would be better to defer the hearing than to extend the period between hearing and judgment.
+The reader may think the JCIO is absolutely right.  But the message has not reached the FTT.  I have not done a full survey - though someone should - but note that in 2025, Judge Geraint Williams brought out ''two'' decisions more than ''eighteen'' months after the hearings,<ref>''Lloyds Asset Leasing Ltd v HMRC'' [2025] UKFTT 57 (TC) decision 20 Jan 2025, hearing dates 5-26 May 2023; ''HMRC v Asset House Piccadilly Ltd'' decision 12 February 2025, hearing dates 12-16 June 2023.</ref> without any adverse comment that I have noticed.  If the problem is acknowledged, the solution seems attainable.  There should be a target date for judgements (from 3 weeks for simple cases to 6 weeks for the most complex) and scheduling of hearings which allows judges to achieve it; and if there have to be years of delay, which of course there should not be, it would be better to defer the hearing than to extend the period between hearing and judgment.
 ===Simplification/complification===
@@ Line 100: / Line 100: @@
 The OTS estimated HMRC guidance at 90,000 pages in 2018;<ref>OTS, “Guidance for taxpayers: a vision for the future” (2018) para 1.21.  These pages have assuredly not been printed or counted.  Quantification raises methodological issues which deserve a short essay to itself.  We have reached the stage where the amount of HMRC guidance is impossible to quantify: the words are uncountable.  Within the limits of guesswork, and assuming 500 words per page (single spacing), the figure of 90,000 pages seems to me to be on the low side.  There are 150 HMRC Manuals, just for a start.
-Perhaps the focus of enquiry should be whether HMRC guidance is too short, because 90,000 pages would not be sufficient to do justice to the topic. The legislation, measured by pages of the Orange & Yellow tax handbooks, can be counted and amounts to 20,836 pages in 2020/21 (that does not include DTAs, which would be another 3,000 pages).  The Tax Cases reports, which began in 1875, and ceased publishing in 2014, reached 82 volumes and did not cover VAT.</ref> whatever the true figure, it will have grown considerably since then.  This guidance was “not comprehensive” - something of an understatement; but according to the OTS “real life cannot be reduced to a neat description in a few (!) pages of writing”.<ref>Para 1.24.</ref>
+Perhaps the focus of enquiry should be whether HMRC guidance is too short, because 90,000 pages would not be sufficient to do justice to the topic. The legislation, measured by pages of the Orange & Yellow tax handbooks, can be counted and amounts to 23,374 pages in 2025/26 (that does not include DTAs, which would be another 3,000 pages).  The Tax Cases reports, which began in 1875, and ceased publishing in 2014, reached 82 volumes and did not cover VAT.</ref> whatever the true figure, it will have grown considerably since then.  This guidance was “not comprehensive” - something of an understatement; but according to the OTS “real life cannot be reduced to a neat description in a few (!) pages of writing”.<ref>Para 1.24.</ref>
 It is easier to ''talk'' of simplification.  In the ill-fated “mini” budget of October 2022:
@@ Line 135: / Line 135: @@
 Comments from my readers and clients continue to be of the greatest value and interest.  I am very grateful to all who commented, and in particular to John Barnett and Sam Dewes (who commented on a variety of topics), and Mark Pearce (cryptoassets).  In order not to be defeated by the size of this work, readers' help is needed more than ever.  If anyone would like to offer to write or revise a section - or chapter - of this book please get in touch.
-The pleasure in writing this book consists in the interest of the questions which it raises, and the success which it may have achieved in answering them.  On the basis of what is known at 1 April 2025, it seeks to state the law for 2025/26.
+The pleasure in writing this book consists in the interest of the questions which it raises, and the success which it may have achieved in answering them. On the basis of what is known at 1 April 2025, the printed book seeks to state the law for 2025/26.  The online version aims to cover some subsequent developments.
 {|
@@ Line 170: / Line 170: @@
 ===Disclaimer===
-The professional bodies issue the <i>Professional Conduct in Relation to Taxation </i> with a disclaimer:
+The professional bodies issue the <i>Professional Conduct in Relation to Taxation </i> with a disclaimer. The Forward provides::
-:While every care has been taken in the preparation of this guidance<ref>PCRT is not in fact guidance: it is mandatory</ref> the PCRT Bodies do not undertake a duty of care or otherwise (?) for any loss or damage occasioned by reliance on this guidance.  Practical guidance cannot and should not be taken to substitute appropriate legal advice.<ref><i>Professional Conduct in Relation to Taxation</i> (2019), Forward.
+:While all reasonable care has been taken in the preparation of this document, the PCRT Bodies do not owe any duty of care and as a result cannot be held responsible for any loss or damage caused by any reliance on this document. This document is not a substitute for appropriate legal advice.
-:<i>https://www.tax.org.uk/professional-standards/professional-rules/professional-conduct-relation-taxation</i>
-The second sentence is an improvement on the common form that guidance on legal issues “does not constitute legal advice”. At first I thought this was just an idiosyncratic use of the word “advice”; but on reflection, it is a euphemism, meaning, the reader cannot rely on what the author is saying, but the author does not want to say that quite so starkly.  For the meaning of “advice” see too  see [[Customer Due Diligence#Tax adviser | Tax adviser]]</ref>
-When that appeared in 2011 it seemed extraordinary.  But nowadays no professional body issues guidance without a disclaimer.<ref> For instance, the Law Society likewise issue a disclaimer for their Practice Notes: The standard form is:
+When that appeared in 2011 it seemed extraordinary.  But nowadays no professional body issues any statement or guidance without a disclaimer.<ref> For instance, the Law Society likewise issue a disclaimer for their Practice Notes: The standard form is:
 :“While care has been taken to ensure that they are accurate, up to date and useful, the Law Society will not accept any legal liability in relation to them.”  </ref>   Similarly, and ''a fortiori'', the views expressed in this book are put forward for consideration only and are not to be relied upon.  Neither the author nor the publisher accept responsibility for any loss to any person arising as a result of any action or omission in reliance on this work.  But could anyone have thought that a claim might arise in absence of this disclaimer?