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Issue:
4466
/
Categories:
Comment & Analysis
, Admin
, Income Tax
, International
, Residence & domicile
Departing the UK is often easier than getting out of its tax system
KEY POINTS
- The introduction of the statutory residence test provides more certainty over residence status now that lifestyle factors are less important.
- Ensure that income and gains are not caught by UK tax when split-year treatment is not available or there is an early return to the UK.
- Entitlement to UK personal allowances for non-residents has been restricted; some UK source income will potentially remain subject to tax and income from UK property has its own regime.
- The five-year rule for the taxation of UK gains now applies from the date of departure rather than referring to complete tax years.
- Do not overlook the implications of the tax regime in the destination country – there may be advantages to retaining a UK liability.
Practitioners dealing with internationally-biased private clients will...
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