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UK allowances

01 October 2013
Issue: 4422 / Categories: Forum & Feedback , Double taxation , Residence & domicile

Is a Pakistani taxpayer entitled to personal allowances to set against rental income arising in the UK during a period of non-residence? The complication is that the taxpayer is working in Dubai

I have a client of Pakistani domicile of origin who is presently employed in Dubai having left the UK (where he had been ordinarily resident) in 2011/12. His current overseas employment is full-time and effectively open-ended.

In 2012/13 he is non-resident and (I have concluded) not ordinarily resident. My question is with regards to his entitlement to the UK personal tax allowance and whether this is available to be set against his UK property profits.

In so far as I can see the only possibility of entitlement to the relief is under the double tax treaty with Pakistan.

However my reference material (including Tolley’s Income Tax and Simon’s Direct Taxes) states that the relief is available to a “resident” of the other state. In my client’s case he is resident in Dubai and thus on the face of it he has no...

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