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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.12 Sale of income from personal occupation /Avoidance rules, sale of income from personal occupation / E1.1206 Residence matters
Commentary

E1.1206 Residence matters

Personal and employment tax

The occupation in question must be carried on, wholly or partly, in the UK, though there is no requirement for the individual to be resident in the UK1.

HMRC's interpretation of this rule is as follows2:

  1. Ìý

    •ÌýÌýÌýÌý where the occupation is carried on wholly in the UK, the whole of the gain

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