Readers’ forum: Residence status

Having recently completed the tax return of a client who has always been non-UK resident and who disposed of a residential UK property in 2019-20 I was wondering whether UK residence at an earlier point would make a difference to the tax treatment.

In other words if a UK resident leaves the UK in 2021 (with no intention to return) and subsequently disposes of UK residential property – would the provisions applicable to disposals by non-residents (such as an optional 2015-rebasing election or a time apportionment of the gain) be available by virtue of the non-resident status at the time of disposal? Alternatively would the former UK resident status deny this treatment (and presumably tax the non-resident on the basis as a UK resident)?

Readers’ comments would be much appreciated.

Query 19 717 – Brexitor.

Temporary non-resident rules don’t apply to disposal if permanently non-resident.

Prior to...