It has been suggested that substantially all British humour of the last half century, from Monty Python onwards, derives from BBC Radio’s Goon Show, the madcap 1950s antics of Spike Milligan, Peter Sellers and Harry Secombe. Perhaps the most iconic moment in the ‘Last Good Show Of All’ (no prize for guessing where that came in the episode timeline) is when householder Ned Seagoon (Secombe) discovers the coalman, the halfwit Eccles (Milligan), in his coal cellar at 3 o’clock in the morning:

‘What are you doing here?’

‘Everybody’s godda be somewhere.’

Well, throughout a long career, my starting assumption about individual taxpayers has been that they always must be tax resident somewhere.  There have been odd occasions where that assumption has been challenged: the bloke who lived on a yacht; the 90 year old tax exile who counted every minute of every day as he flitted between homes in various countries. But those were the exceptions.

Because establishing residence is incredibly important, in many countries a resident being taxable on his worldwide income while a non-resident is either non-taxable or only taxed on local sourced income, individual nations tended to draw their lines in the sand quite early on. There were those who used subjective tests based on where an individual’s centre of personal and economic interests or habitual abode were, others who looked at the owning of an occupiable home, others who used quantitative (number of days) tests, the all-time favourite being presence of over 183 days in the tax year, and others who used a combination of the foregoing. As countries that could be bothered with these things tended to be quite developed, they also tended to have many bi-national double taxation treaties that took precedence over the quantitative equations and other tests enshrined in local law when there was a dispute about residence, and concentrated on an agreed list of tests, the most important of which was the highly subjective ‘centre of vital interests’.

Thus, unless an individual was going off to live in Bongo-Bongo Land, in which case they probably needed all the fiscal help they could get, it was likely to be the OECD tax treaty definition all the way.

Israel is developed, it has about 50 tax treaties with virtually every country that is likely to attract Israelis (Cyprus and New Zealand are notable exceptions), and ever since it went over to a worldwide basis of taxation it has had quantitative rules (albeit refutable presumptions) to reinforce its subjective ‘centre of life’ definition. Welcome to the 21^st century.

So why, oh why, has a proposed amendment to the law just been placed before the Knesset full of horribly complex numbers involving – in addition to the current statistics – days present over numbers of years but not if there is a January, February, November or December in the date (although February and November are sometimes included), further adjusted if an individual’s spouse and kids came along for the ride? Not to mention the need for a certificate of residence from a treaty country with an opposing claim to residency – a requirement that has been fairly standard since I got into this game in the 1980s.

In short, to quote – for the sake of balance – one of the US’s founding fathers of modern comedy: ‘Here’s another fine mess you’ve gotten me into.’

I am going to sit this out until this superfluous piece of legislation passes in its final (I assume, quite different) form. The current situation is too embarrassingly complex. Watch this space, but if it’s New Zealand or Cyprus for you, now might be the time to talk to someone with a good head for numbers. (other than counting sheep).