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UK non-resident individuals are not taxable in the UK on their foreign income.

However, there are anti-avoidance provisions relating to dividends paid by certain non-resident companies where the individual is temporarily non-resident.

The temporary non-residence rules apply where an individual has been resident in the UK at any time during at least four of the seven tax years prior to departure and is non-resident in the UK for five years or less. Where this is the case, the anti-avoidance rules mean that certain types of income and capital gains which arose during the period of non-residence are taxed in the tax year in which the individual returns to the UK (termed the 'period of return' in the legislation). The rules apply where the individual's 'year of departure' from the UK is 2013/14 or later. For detailed discussion of the meaning of these terms, see E6.137B. For a list of the types of income and gains that are subject to the temporary non-residence rules, see E6.137A.¹

In relation to close companies,