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My client is in the army and has been posted to Cyprus for three years. He will meet the automatic not resident tests for statutory residence purposes but as he is continuing to be paid by the army will be treated as UK resident for income tax purposes.
He has recently received a substantial amount of money from the liquidation of a family company in the UK which had UK property as more than 75% of its balance sheet. These properties were sold so that cash was distributed on liquidation.
I am unclear as to the correct reporting of this gain. I believe that the liquidation of the company would be outside the scope of capital gains tax unless my client returns to the UK in less than five years but is the disposal caught by the non-resident capital gains tax (NRCGT) rules for...
