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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.1 Residence status /Liability of non-residents / E6.126 Limit on the income tax liability of non-residents
Commentary

E6.126 Limit on the income tax liability of non-residents

Personal and employment tax

Usually, non-residents are liable to UK income tax on their UK source income for the tax year.

This basic rule is subject to:

  1. Ìý

    •ÌýÌýÌýÌý provisions in the double tax treaty that the UK has with the jurisdiction in which the individual is resident which exempt UK income from tax in the UK or otherwise limit the amount of UK income tax payable on that income (see E6.125 (individuals) and D4.115 (companies)), and

  2. Ìý

    •ÌýÌýÌýÌý the limit on the UK income tax liability of a non-resident under the rules in ITA 2007, ss 811–828 (discussed below)

Limit on UK income tax liability of non-resident

To summarise, the limit on the UK income tax liability of a non-resident individuals means that the UK income tax liability cannot exceed the total of1:

  1. Ìý

    •ÌýÌýÌýÌý Amount A – the tax deducted at source (if any) from disregarded income, plus

  2. Ìý

    •ÌýÌýÌýÌý Amount B – the tax due on all taxable UK source income, excluding disregarded income. The UK income tax

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Web page updated on 17 Mar 2025 16:39