E6.137A Temporary non-residence—overview
Becoming non-resident in the UK for a temporary period has long been recognised as an avoidance opportunity. In the absence of anti-avoidance legislation, an individual could leave the UK, realise income or gains during a short period of non-residence which would not be liable to tax in the UK, and then return to the UK.
The temporary non-residence rules are designed to stop people from becoming non-UK resident for a relatively short time and then, during this period, crystallising income or gains which are not taxable in the UK due to the person's residency status. This UK tax avoidance is prevented by taxing the income and gains in the tax year in which the individual returns to the UK.
Initially,
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