In a speech to be delivered at the University of Warwick later today, Miliband will say non-dom status represents an ‘increasingly arcane 200-year-old loophole’, with ‘no other major country in the developed world’ offering a similar kind of tax break.

‘There are now 116,000 non-doms, costing hundreds of millions of pounds to our country, it can no longer be justified, and it makes Britain an offshore tax haven for a few,’ Miliband will say.

According to the draft of his speech released ahead of the event, Miliband will say that current tests to determine non-dom status are ‘old fashioned’ and insufficiently rigorous, claiming they are based on whether someone owns property or a burial plot abroad, or has a father born abroad. 

He also claims that as well as allowing wealthy people to avoid paying tax on overseas income, the current non-dom rules also allow non-doms to use offshore trusts to buy UK homes and avoid UK inheritance tax, or to set up loan arrangements and receive repayments tax free. 

Miliband will say: ‘I want to be clear: I don’t blame people for taking advantage of non-dom status. I blame governments for fostering a system that can be taken advantage of.’

The speech outlines plans for the next Labour government to abolish the non-dom rule and replace it with what Miliband calls ‘a clear principle: anyone permanently resident in the UK will pay tax in the same way.’

Under Labour plans, non-dom status will be abolished so that everyone who comes to the UK and makes the UK their permanent home pays tax in the same way from April 2016.

There will be new rules for temporary residents so that only those in the UK for a short period – for example to study or through their work – would only be taxed on income and gains in the UK.

A future Labour government will consult on the length of time for which the new rules for temporary residents should apply and on the transition period over which existing non-doms will come within them, with four years suggested as the likely timeframe.

Conservative Chancellor George Osborne tightened up the non-dom rules in his last Autumn Statement, increasing the annual charge for non-doms who have lived in the UK for 17 of the last 20 years from £50,000 to £90,000. The annual charge for those who have been in the UK for the more than seven years is £30,000.

Issues around non-dom status were raised recently during Parliamentary committee evidence sessions examining the alleged use by UK taxpayers of HSBC’s private Swiss bank to handle offshore funds. Stuart Gulliver, HSBC’s chief executive, has non-dom status despite running a UK-headquarted bank and being based in the UK himself.