The effect of the abolition of substantial tax relief on dividends that pension funds received on their investments

[Lootman]

Moderator Message:
Split off from here to keep that discussion on topic. Not sure if this is the right place for it either. Please suggest (and self-report) an alternative place if you feel strongly about it. Thanks. - Chris

Withholding tax is not levied on British shares, even if like Smith & Nephew they pay US dollar dividends (American shares OTOH have 15% or 30% withholding tax deducted from their dividends).

Yes, there is no withholding tax on UK shares even for foreign holders of UK shares. And no UK CGT applies to foreign holders either. So UK shares are very tax-friendly for foreign entities and individuals to hold, although of course local taxes may be due.

Note however this was not always the case. There used to be tax withholding on UK dividends, called a tax credit, of 10%. This was reclaimable by a non-taxpayer such as a pension fund, a charity or an ISA. This was abolished by Gordon Brown, and widely criticised at the time as one of his "stealth taxes", and as "the Great British Pension Robbery":

"The chancellor, Gordon Brown, abolished substantial tax relief on dividends that pension funds received on their investments.

The financial effect of this tax snatch was colossal. It was estimated that the loss of this tax relief had extracted, in total, over £118 billion of income by 2014. If this lost income had been even conservatively invested, pension funds may have benefited by an additional £230 billion."

https://theconversation.com/britains-gr ... ast-100844

So the idea that you get the "full" dividend is a bit of a myth, at least if you are a non taxpayer.

[Alaric]

The financial effect of this tax snatch was colossal. It was estimated that the loss of this tax relief had extracted, in total, over £118 billion of income by 2014. If this lost income had been even conservatively invested, pension funds may have benefited by an additional £230 billion."

It was never really a lost tax relief, more of an abolished subsidy to pension funds and other gross investors. For a while until Gideon introduced the £ 5000 limit, it was a level playing field as far as tax on dividends was concerned between investment via pensions or ISAs and direct holdings.

[Lootman]

The financial effect of this tax snatch was colossal. It was estimated that the loss of this tax relief had extracted, in total, over £118 billion of income by 2014. If this lost income had been even conservatively invested, pension funds may have benefited by an additional £230 billion."

It was never really a lost tax relief, more of an abolished subsidy to pension funds and other gross investors. For a while until Gideon introduced the £ 5000 limit, it was a level playing field as far as tax on dividends was concerned between investment via pensions or ISAs and direct holdings.

But the effect of it was to divert money from non-taxpayers to the government.

Take the example of a share that was priced at £20 and paid out a dividend of £1 a year per share. The actual net payout was 90p, with a 10p withholding or credit. A non-taxpayer could claim that back, meaning that he gets the full (gross) £1.

After the change, he still got that 90p but there was no ability to reclaim the rest. He basically went from getting a gross dividend to getting a net dividend.

And the dividend yield quoted in the FT went from 5% to 4.5% overnight.

Over the years those dividends have been increased and we have all forgotten about it. But at the time it was a 10% tax raid on dividends, and the effect of that continued and was cumulative, which is where those £118 billion and £230 billion amounts come from.

[XFool]

Yes, there is no withholding tax on UK shares even for foreign holders of UK shares. And no UK CGT applies to foreign holders either. So UK shares are very tax-friendly for foreign entities and individuals to hold, although of course local taxes may be due.

Note however this was not always the case. There used to be tax withholding on UK dividends, called a tax credit, of 10%. This was reclaimable by a non-taxpayer such as a pension fund, a charity or an ISA. This was abolished by Gordon Brown, and widely criticised at the time as one of his "stealth taxes", and as "the Great British Pension Robbery":

"The chancellor, Gordon Brown, abolished substantial tax relief on dividends that pension funds received on their investments.

Ahrgh! All the usual stuff... It's like The Night of the Living Dead, this will never die.

"There used to be tax withholding on UK dividends, called a tax credit, of 10%." - Only if you can manage to convince yourself that a "credit" is a "debt" (i.e. a witholding tax)

Sorry! I just CAN'T any longer bring myself to explain this yet again - not after all this time. Let it die. Please let it finally die, for Gawd's sake!

Anyone else?

PS. The most I will do is to refer you to relevant posts made by the late Gengulphus.

[Lootman]

Yes, there is no withholding tax on UK shares even for foreign holders of UK shares. And no UK CGT applies to foreign holders either. So UK shares are very tax-friendly for foreign entities and individuals to hold, although of course local taxes may be due.

Note however this was not always the case. There used to be tax withholding on UK dividends, called a tax credit, of 10%. This was reclaimable by a non-taxpayer such as a pension fund, a charity or an ISA. This was abolished by Gordon Brown, and widely criticised at the time as one of his "stealth taxes", and as "the Great British Pension Robbery"

"The chancellor, Gordon Brown, abolished substantial tax relief on dividends that pension funds received on their investments".

I just CAN'T any longer bring myself to explain this yet again -

To my knowledge you have never "explained" to anyone's satisfaction why this is/was a non-issue. And indeed, why would Brown have made the change if it had zero effect as you claim?

And it was not just pension accounts. Anyone with an ISA saw a drop in their dividends, as did anyone who did not have enough income to owe income tax. I have statements I could show you that document the proof of that drop in income.

[Alaric]

And indeed, why would Brown have made the change if it had zero effect as you claim?

It did something to corporate accounting. I think the position before the change was that the difference between a notional gross dividend and the net one actually paid could be used by Companies to offset their Corporation Tax bills. The phrase "Advance Corporation Tax" comes to mind.

https://www.investopedia.com/terms/a/ad ... on-tax.asp

Gordon Brown believed there was too much abuse by companies and pension funds claiming repayment of the ACT. In place of a company’s obligation to pay ACT, he substituted an obligation for larger companies to pay their corporation taxes in installments. Tax credits were also no longer repayable to companies, pension funds, or individuals.

[Lootman]

And indeed, why would Brown have made the change if it had zero effect as you claim?

It did something to corporate accounting. I think the position before the change was that the difference between a notional gross dividend and the net one actually paid could be used by Companies to offset their Corporation Tax bills. The phrase "Advance Corporation Tax" comes to mind.

https://www.investopedia.com/terms/a/ad ... on-tax.asp

Gordon Brown believed there was too much abuse by companies and pension funds claiming repayment of the ACT. In place of a company’s obligation to pay ACT, he substituted an obligation for larger companies to pay their corporation taxes in installments. Tax credits were also no longer repayable to companies, pension funds, or individuals.

Yes and it was the fact that "Tax credits were also no longer repayable to companies, pension funds, or individuals" which was widely described as a "theft" at the time, and since. In effect everyone from that date could only receive a net dividend; gross dividends vanished.

Higher rate taxpayers had more tax to pay of course. It made no difference to basic rate taxpayers. But non-taxpayers lost out, to the tune of that 10% difference between net and gross.

[XFool]

I just CAN'T any longer bring myself to explain this yet again -

To my knowledge you have never "explained" to anyone's satisfaction why this is/was a non-issue. And indeed, why would Brown have made the change if it had zero effect as you claim?

You are missing the point entirely, which is the point. You are confounding different things. (Due to your usual political prejudices)

It is not the complete story but anyone genuinely interested can do worse than read this: https://en.wikipedia.org/wiki/Advance_corporation_tax

[Nocton]

Lootman said: "Higher rate taxpayers had more tax to pay of course. It made no difference to basic rate taxpayers. But non-taxpayers lost out, to the tune of that 10% difference between net and gross."

In fact it did make a difference to basic rate tax payers as my wife and I found. We give a lot to charity each year and the tax credit was effectively part of the tax paid each year. Without it, we had less tax to offset against the gifts paid to charities, meaning that in the year the change was made we found we had to pay extra tax to make up the 25% charities took for gift aid. The following year, like many others, we reduced the amount we gave to charities, one of the reasons IMO that the amount received by charities decreased in subsequent years.

[ursaminortaur]

Lootman said: "Higher rate taxpayers had more tax to pay of course. It made no difference to basic rate taxpayers. But non-taxpayers lost out, to the tune of that 10% difference between net and gross."

In fact it did make a difference to basic rate tax payers as my wife and I found. We give a lot to charity each year and the tax credit was effectively part of the tax paid each year. Without it, we had less tax to offset against the gifts paid to charities, meaning that in the year the change was made we found we had to pay extra tax to make up the 25% charities took for gift aid. The following year, like many others, we reduced the amount we gave to charities, one of the reasons IMO that the amount received by charities decreased in subsequent years.

Gordon Brown just made the tax credit notional rather than something which could be reclaimed by non-taxpayers. The amount of tax you were deemed to have paid still included that tax credit (ie on your self assessment you added the notional tax credit to dividend payments which meant you were deemed to have paid that tax and reached the 40% tax band sooner). It would presumably be George Osborne's complete abolition of that notional tax credit in 2016 which would have then affected your charity giving rather than Brown's changes. That change by Osborne also of course affected basic rate tax payers by making them pay 7.5% tax on everything over the, then £5000 but ever thereafter reducing, dividend allowance rather than the zero they had paid previously so long as they remained basic rate taxpayers.

[scrumpyjack]

I remember when I started investing in 1971 companies paid, I think, 40% corporation tax then paid dividends with no offset for the CT paid and the investor was then taxed on the dividend at their highest rate plus the 15% 'unearned' income surcharge, so the top rate of tax for dividends was 98% and that started at £2,000 of income as I recall. The only relief was that one could set gross dividends against mortgage interest paid (interest was tax deductible without limit at that time). So, if you had dividend income, you were incentivised to buy the biggest house you could, borrowing as much as you could!

[Lootman]

Lootman said: "Higher rate taxpayers had more tax to pay of course. It made no difference to basic rate taxpayers. But non-taxpayers lost out, to the tune of that 10% difference between net and gross."

In fact it did make a difference to basic rate tax payers as my wife and I found. We give a lot to charity each year and the tax credit was effectively part of the tax paid each year. Without it, we had less tax to offset against the gifts paid to charities, meaning that in the year the change was made we found we had to pay extra tax to make up the 25% charities took for gift aid. The following year, like many others, we reduced the amount we gave to charities, one of the reasons IMO that the amount received by charities decreased in subsequent years.

Gordon Brown just made the tax credit notional rather than something which could be reclaimed by non-taxpayers. The amount of tax you were deemed to have paid still included that tax credit (ie on your self assessment you added the notional tax credit to dividend payments which meant you were deemed to have paid that tax and reached the 40% tax band sooner). It would presumably be George Osborne's complete abolition of that notional tax credit in 2016 which would have then affected your charity giving rather than Brown's changes. That change by Osborne also of course affected basic rate tax payers by making them pay 7.5% tax on everything over the, then £5000 but ever thereafter reducing, dividend allowance rather than the zero they had paid previously so long as they remained basic rate taxpayers.

That sounds about right. The article I cited upthread notes that it was not Brown alone that tinkered with pensions and taxes to negative effect. Although perhaps no other politician was so "clever" about it. At the time many pension funds were running surpluses and taking contribution holidays. Brown saw that as a ripe source of tax revenues and found a back door way of (effectively) taxing them.

Of course it was not just pensions affected but any non-taxpayer. Back in the 1990s our children were very young and my wife took a few years off work to look after them. She had no income and so was a non-taxpayer. I transferred my dividend-paying shares to her, and she was able to claim back that 10%. She simply sent off the annual set of dividend vouchers to the taxman, who then sent her a cheque for 11.11% (10/9) of the amount she had actually received net.

This typically came to a few hundred pounds a year. Brown's change removed that ability, thereby reducing her dividend income by 10%. As it happened, she went back to work the next year so it was moot. But it shows how Brown managed to find a way to tax even low-paid non-taxpayers!

IIRC the Tories vowed to reverse Brown's change, but in fact they just made it even worse.

[XFool]

Of course it was not just pensions affected but any non-taxpayer. Back in the 1990s our children were very young and my wife took a few years off work to look after them. She had no income and so was a non-taxpayer. I transferred my dividend-paying shares to her, and she was able to claim back that 10%. She simply sent off the annual set of dividend vouchers to the taxman, who then sent her a cheque for 11.11% (10/9) of the amount she had actually received net.

The tax witheld from dividends, when they were paid Nett of tax in the 1990s under the ACT regime, was 20% not 10%. To wit, my Nelson Cobbold PEP Account:

05/03/97 DIV FOR 686 BRITISH TELEC £54.19 (Paid Nett of tax)
21/04/97 TAX FOR 686 BRITISH TELEC £13.55 (Reclaimed tax)

Gross BT dividend £54.19 + £13.55 = £67.74

20% of £67.74 = £13.55, the tax reclaimed in the tax free PEP account.

By the time the Tax Credit on share dividends was 10% there was no tax withheld on share dividend payments. They were no longer paid nett of tax, they were just paid. (This is IMO 'The Great Misunderstanding') So no non taxpayer had any reason to suppose tax was available to 'refund'. This was generally the case, however... for 5(?) years the 10% Tax Credit on dividends WAS actually paid to PEP and ISA account holders. Why? My opinion, whether it be right or be wrong, was that it was a pump priming exercise to ease the transition to the new ISAs and help get them off the ground.

The main effect of the 10% tax credit on share dividends was that it zeroed out the effective starting rate of dividend taxation for BR taxpayers which was... 10%! (10% - 10% = 0%). So dividends were generally still taxed (but after receipt), not normally tax free, but the rate of taxation for BR tax payers was 0%. Higher for HR taxpayers.

Simple, though a little odd (it confused many!). Much better for BR taxpayers than the present system, AFAIAC.

[CliffEdge]

I have never forgiven Brown for this heinous crime against pensioners. It eclipses everything else that was done by the Blair/Brown government.
A mean minded Scot.

[Lootman]

Of course it was not just pensions affected but any non-taxpayer. Back in the 1990s our children were very young and my wife took a few years off work to look after them. She had no income and so was a non-taxpayer. I transferred my dividend-paying shares to her, and she was able to claim back that 10%. She simply sent off the annual set of dividend vouchers to the taxman, who then sent her a cheque for 11.11% (10/9) of the amount she had actually received net.

The tax witheld from dividends, when they were paid Nett of tax in the 1990s under the ACT regime, was 20% not 10% . . By the time the Tax Credit on share dividends was 10% there was no tax withheld on share dividend payments. They were no longer paid nett of tax, they were just paid.

Yes, at some point the rate went from 20% to 10%. But the important point was that either way it used to be reclaimable by non-taxpayers, until that was stopped. That was a real loss and cost to those affected.

And yes it had to do with ACT but that was immaterial to those funds and investors who lost their ability to make a reclaim. All they saw was a 10% hit to their income; they generally did not care why or how. And ACT only applied to UK companies and yet the credit was applied also to the dividends of UK funds that invested overseas, which makes a bit of a mockery of the idea that this was all caused by ACT.

for 5(?) years the 10% Tax Credit on dividends WAS actually paid to PEP and ISA account holders.

And that just goes to show that even with ACT, it would have been entirely possible to have retained the ability to reclaim the credit. The government simply decided to do away with it instead, causing the cited losses to income.

I have never forgiven Brown for this heinous crime against pensioners. It eclipses everything else that was done by the Blair/Brown government. A mean minded Scot.

I did not know much about Brown until that point. But for me it was not the cost of this that bothered me so much, as I do not usually invest for dividends anyway. It was that it was done in an underhand way, almost designed to confuse and obfuscate. Blair/Brown had promised no tax increases and this was effectively doing an end run around that promise. If you are going to raise taxes then be honest and open about it.

But as I said before the Tories have had 13 years to fix this and have not. In the end all politicians seem to like stealth taxes. Increasing employer NIC rates is another. Freezing allowances causing fiscal drag is yet another.

[XFool]

The tax witheld from dividends, when they were paid Nett of tax in the 1990s under the ACT regime, was 20% not 10% . . By the time the Tax Credit on share dividends was 10% there was no tax withheld on share dividend payments. They were no longer paid nett of tax, they were just paid.

Yes, at some point the rate went from 20% to 10%. But the important point was that either way it used to be reclaimable by non-taxpayers, until that was stopped.

Nope.

The witheld tax - with dividends paid nett of tax under ACT - was reclaimable by non-taxpayers. The tax rate in the 1990s was 20%

The 10% Tax Credit was never reclaimable by general non taxpayers. When the 10% Tax Credit was in place the old system, with ACT and tax (20%) witheld on dividends had gone.

The anomaly (which has likely helped the confusion) was the nominal 10% Tax Credit actually being paid to PEP/ISA account holders for a number of years. But, this 10% Tax Credit could not be "reclaimed" by non tax payers in general - no tax had been paid. It could be used to offset tax owed: in particular the basic rate 10% tax on dividends, owed by the recipients of the dividend after receipt of the dividend (dividends were just paid, no gross/nett). As it happened that the starting rate of dividend taxation was itself 10% this meant the tax owed by BR taxpayers was at the effective rate of 10% - 10% = 0%. In general, a non taxpayer could not "reclaim" this 'no tax actually paid' Tax Credit.

https://en.wikipedia.org/wiki/Advance_corporation_tax#History

ACT was scrapped from 6 April 1999, and replaced by a tax credit on dividend income of 10%.

https://webarchive.nationalarchives.gov.uk/ukgwa/20100512164411/http://www.hmrc.gov.uk/consult/consult_2.htm

A modern system for Corporation Tax payments

https://webarchive.nationalarchives.gov.uk/ukgwa/20100512164411/http://www.hmrc.gov.uk/consult/consult_2.htm#6.%20Taxation%20of%20shareholders'%20dividends

UK individual shareholders
6.3. Individual shareholders whose income is within the lower or basic rate bands will be liable to tax at 10 per cent on their dividend income. So the tax credit will continue to satisfy their tax liability on UK dividends.

6.4. The higher rate on dividend income will be reduced to 32.5 per cent. This will compensate for the reduction in the rate of tax credits to 10 per cent.

6.5. The treatment of shares held in Individual Savings Accounts will be the subject of separate consultation.

[Henke77]

This thread has been an interesting read for me who had heard about this but didn't really have any interest in it when it was happening. (I was in my early 20s in the late 1990s and the world of investments, pensions and taxes etc were a long way off.)

Without trying to get into politics here (difficult I know) it would seem from my (novice) viewpoint that between 1997 and 1999 it was a bit unfair that ACT was still in place even although non-taxpayers and pension funds couldn't now reclaim it (but maybe this was compensated somewhat due to higher dividends being paid to them as a result of lower corporation tax rates i.e. maybe companies were able to pay higher dividends direct to shareholders due to having to pay less corporation tax although I suspect some of you are thinking pigs might fly at this suggestion - I honestly don't know if this did happen (I suspect it didn't)). However, after ACT was scrapped from 1999 onwards surely it was fair enough that it couldn't be reclaimed as it didn't now exist?

In my view, the newly introduced 10% tax credit post 1999 (which from what I can see had nothing to do with ACT) completely complicated things unnecessarily and caused untold confusion. For example, a company who decided to pay a £90 dividend had to tell the government it was £100 so as to "validate" the 10% tax credit, even although £90 and not £100 came out the company accounts, meaning a basic-rate taxpayer paid an effective rate of 0% tax even although they may have thought they paid 10% due to the tax credit. Even more confusingly, from 1999 to 2004 ISAs used this 10% tax credit to reclaim money that didn't really exist in the first place e.g. £10 in my previous example.

What I would say about the current dividend tax arrangements introduced in 2016-17 is that, from an apolitical viewpoint, they are a lot easier to understand than the previous 10% tax credit arrangements. Whether tax payers, especially basic-rate payers, are better off with them I'll leave for others to argue over.

Finally apologies if anything I have said is totally incorrect! It is just my understanding based on what I have read in the last few days. Hopefully someone will find it useful. (I have tried to steer clear of political debate.)

[Lootman]

In my view, the newly introduced 10% tax credit post 1999 (which from what I can see had nothing to do with ACT) completely complicated things unnecessarily and caused untold confusion. For example, a company who decided to pay a £90 dividend had to tell the government it was £100 so as to "validate" the 10% tax credit, even although £90 and not £100 came out the company accounts, meaning a basic-rate taxpayer paid an effective rate of 0% tax even although they may have thought they paid 10% due to the tax credit. Even more confusingly, from 1999 to 2004 ISAs used this 10% tax credit to reclaim money that didn't really exist in the first place e.g. £10 in my previous example.

Yes, we went from a system where there was a a net and a gross dividend, to a system where there was a net and a grossed-up dividend, to a system where there was only a net dividend. That gross dividend (and so the ability to actually receive it) was gradually phased out. This had the effect of lowering stated dividend yields by 10%.

So if a share was yielding 4% before, it yielded 3.6% after, other things staying equal. Now your point that a lower rate of corporate tax might enable higher dividend payouts to compensate for the loss of the ability to reclaim tax credits is a plausible one. Certainly the tax rates on dividends are lower because of the double taxation of dividends. But it is hard to prove either way whether dividends were raised specifically for that reason, and whether by enough to compensate for the loss.

this 10% Tax Credit could not be "reclaimed" by non tax payers in general - no tax had been paid. It could be used to offset tax owed: in particular the basic rate 10% tax on dividends, owed

It comes to the same thing. A 10% tax credit takes care of my tax obligation if 10% is my marginal tax rate, sure. But if my marginal tax rate is 0% then that credit is effectively wasted and worth nothing to me.

That means that a non-taxpayer basically nets the same amount as a basic-rate taxpayer, and that was why there was outrage at the time, such as this:

British Conservatives accused the chancellor, Gordon Brown, yesterday of orchestrating "the great British pension theft", as they moved a motion of no confidence in his handling of retirement savings.

Shadow chancellor George Osborne told a stormy House of Commons that the abolition of dividend tax credits in the 1997 budget was Mr Brown's "first and worst stealth tax", amounting to a £100 billion (€147 billion) raid on pension funds.

https://www.irishtimes.com/news/labour- ... -1.1202260

[Charlottesquare]

This thread has been an interesting read for me who had heard about this but didn't really have any interest in it when it was happening. (I was in my early 20s in the late 1990s and the world of investments, pensions and taxes etc were a long way off.)

Without trying to get into politics here (difficult I know) it would seem from my (novice) viewpoint that between 1997 and 1999 it was a bit unfair that ACT was still in place even although non-taxpayers and pension funds couldn't now reclaim it (but maybe this was compensated somewhat due to higher dividends being paid to them as a result of lower corporation tax rates i.e. maybe companies were able to pay higher dividends direct to shareholders due to having to pay less corporation tax although I suspect some of you are thinking pigs might fly at this suggestion - I honestly don't know if this did happen (I suspect it didn't)). However, after ACT was scrapped from 1999 onwards surely it was fair enough that it couldn't be reclaimed as it didn't now exist?

In my view, the newly introduced 10% tax credit post 1999 (which from what I can see had nothing to do with ACT) completely complicated things unnecessarily and caused untold confusion. For example, a company who decided to pay a £90 dividend had to tell the government it was £100 so as to "validate" the 10% tax credit, even although £90 and not £100 came out the company accounts, meaning a basic-rate taxpayer paid an effective rate of 0% tax even although they may have thought they paid 10% due to the tax credit. Even more confusingly, from 1999 to 2004 ISAs used this 10% tax credit to reclaim money that didn't really exist in the first place e.g. £10 in my previous example.

What I would say about the current dividend tax arrangements introduced in 2016-17 is that, from an apolitical viewpoint, they are a lot easier to understand than the previous 10% tax credit arrangements. Whether tax payers, especially basic-rate payers, are better off with them I'll leave for others to argue over.

Finally apologies if anything I have said is totally incorrect! It is just my understanding based on what I have read in the last few days. Hopefully someone will find it useful. (I have tried to steer clear of political debate.)

We do all also remember that ACT was Advance Corporation Tax (CT paid in advance) , when a dividend was paid the company, quarterly declared on a CT61, paid over this tax to HMRC, it was however offset against the mainstream Corporation Tax payable at the year end. So say company paid net dividend of £80, it then paid ACT of say £20 to HMRC. Depending on CT rate on the £100 of profits (pre dividend) it was due to pay, say 25% CT, so £25 due less £20 ACT already paid, balance £5 still to pay. (All rates made up as I cannot remember them)

The system was in place to encourage companies to distribute, they would pay CT whether they had or had not paid dividends and if company went a few years without paying divs when they later did you could have surplus ACT that could not easily be relieved. You could get the position of ACT paid out greater than CT due, in which case the ACT often got carried forward and used in interesting ways that these days I cannot remember. (somewhere I have a handy textbook with all this explained and worked examples with interaction of losses, ACT, carry forwards etc)

[77ss]

....
But as I said before the Tories have had 13 years to fix this and have not. In the end all politicians seem to like stealth taxes. Increasing employer NIC rates is another. Freezing allowances causing fiscal drag is yet another.

What makes you think that the Conservatives want to 'fix' this?

As ever, certain posters conveniently forget that the process was initiated by Lamont. Just completed by Brown.

Once a certain 'relief' - call it what you will - has been targeted, then it is often just a question of time before it is again targeted - irrespective of the governments involved.