I think that my noble friend is missing the point that is being made; namely, that the Revenue is able to deal with people who are flitting in and out of being liable for UK tax. It has nothing to do with the test of residency. In this case, it is about fairness and whether you are liable for the tax arising from whether you are a Scottish taxpayer or an English taxpayer. The noble Lord was simply making a parallel case and asking why the Revenue can accommodate some people. I suspect the reason is that there are a few of them and they pay a lot in tax. The Inland Revenue might look at this and say, "Oh well, we could have a lot of people who might be moving and it will be difficult". I thought that the whole argument for this was based on it being terribly simple because it simply means changing someone's tax code. Tax codes are changed all the time. What is so difficult about changing someone's tax code when they have moved from Scotland to somewhere else or to change their liability for Scottish income tax during the course of the tax year?