241 Pizza

The analysis found evidence that one of the 54, the Fleming family banking dynasty, had paid capital gains tax — £4.5m — which is levied on the sale of companies, shares and second homes. They declined to comment.

Of the 22 billionaires who paid tax, this was mostly on share dividends paid by their companies. The wealthy usually choose to pay themselves in dividends rather than with a conventional salary — as the tax on dividends is at an effective rate of 25% rather than the 40% higher rate of income tax.

The analysis also reveals widespread use of offshore tax havens by the super-rich. This is made possible through loopholes that the chancellor has been reluctant to close. At least 42 of the 54 billionaires make use of havens such as the Channel Islands, Switzerland and the Caribbean.

For example, Sir Richard Branson has a complicated series of offshore trusts and companies that own his business empire. Branson, whose wealth is calculated at £3,065m, pays relatively little tax as his wealth is tied up in these companies.

It means that when he retires, he could move abroad — to the island he owns in the Caribbean — and liquidate his assets virtually tax-free. Branson declined to comment.

The most common loophole used by billionaires is to take advantage of the British system of offering “non-domicile” status to foreigners, or those with foreign-born parents, living in this country.

Under the scheme, wealthy foreigners can legitimately claim they are “domiciled” abroad even though they may carry British passports and may have lived in Britain for decades. So-called “non-doms” place their assets in offshore tax havens and pay tax only on money brought into Britain.

Bernie Ecclestone, the Formula One racing tycoon, has benefited from the loophole. He said he transferred the shares in his company to his wife when he was ill.

“She subsequently sold the shares; she was domiciled abroad. You need to give people an incentive to make money. The lower the tax, the more incentive. I could run the company from anywhere in the world, but I would rather live in England and pay my taxes,” he said.

Brown promised to scrap the loophole when in opposition and it has been “under review” for many years. It is believed the Treasury has concluded that non-doms bring significant economic benefit to the country and they would simply leave — rather than pay tax — if the system was changed. Among those who benefit from the loophole are Lakshmi Mittal, Britain’s richest man with a fortune of £14.8 billion; the Hinduja brothers; Roman Abramovich, owner of Chelsea football club; and Poju Zabludowicz, who owns several Las Vegas casinos but lives in London.

Chris Hancock, a vice-president of JP Morgan private bank, said: “The UK is a pretty benign tax regime for people who come to live here from overseas.

“It’s arguably an onshore tax haven. However, the withdrawal of tax-favoured status to the non-domicile community would have a major impact on the attractiveness of London as a place to work and could damage London’s status as one of the financial centres of the world.”

Other billionaires with British roots benefit from another loophole in the tax laws — by becoming so-called non-residents. This allows them to move abroad, typically to a tax haven, but return to this country for a maximum of 90 nights a year.

Additional reporting: Jon Ungoed-Thomas and Tom Baird

Explore Law

• Columnists

• Law Panel

• Law Reports

• Student Law

Times Recommends

• BGC 'set aside £40m to lure Tullett brokers'
• Legal aid review to ensure value
• Fears as 21 magistrates' courts face closure