UK non-resident individuals remain taxable in the UK on their UK source income only. However this is subject to any provisions to the contrary in the relevant double tax treaty between the UK and the jurisdiction in which the individual is resident and the rules that limit UK income tax liability of non-residents. This is discussed further in E6.125.
There are also anti-avoidance provisions relating to close company distributions 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'
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Web page updated on 17 Mar 2025 13:36