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Posted Thu, 29 Feb 2024 14:47:41 GMT by Ann Q
Hi, If a residential property rented out is held under a Limited company (SPV), and the director of the company is non-uk resident. Does the director need to pay UK income tax if getting dividend from the SPV? Thanks.
Posted Fri, 01 Mar 2024 17:17:44 GMT by HMRC Admin 25 Response
Hi 
It depends on what the double taxtion treaty says between the UK and whatever country this director lives in.
Thank you. 
Posted Fri, 01 Mar 2024 22:06:32 GMT by Ann Q
Thanks for the reply. From my understanding, dividend from UK companies paid to Non-uk resident can be treated as 'disregarded income' and therefore not liable to UK income tax. Can you confirm if this is correct? See link below: https://www.gov.uk/hmrc-internal-manuals/savings-and-investment-manual/saim1170 I also found a similar post before (link as below), and HMRC Admin 5 posted 3 months ago that "Individuals who are non resident in the UK are not taxable in the UK on UK interest or dividends received. " It does not mention anything about double taxation treaty. Can you explain a bit more about how double taxation treaty works here? https://community.hmrc.gov.uk/customerforums/pt/d0f9057b-3d87-ee11-a81c-000d3a86dfe6#:~:text=Individuals%20who%20are%20non%20resident,is%20known%20as%20disregarded%20income). Thank you.
Posted Tue, 05 Mar 2024 10:53:01 GMT by HMRC Admin 21 Response
Hi Annie Qu,
Thank you for your question.
Please refer to our helpsheet HS300 Non-residents and investment income (2023) which provides more information about non-residents and investment income and how it is charged to tax.  Non-residents are not taxable on UK dividend income but this should still be declared if completing a Self Assessment tax return, for calculation purposes this will show as ‘Non-UK resident’s disregarded income’.
More information about double taxation and investment income can be found in SAIM1170 - Savings and investment income: non-residents.
Thank you.
Posted Mon, 19 Aug 2024 20:22:39 GMT by SimoneF
Hi I'm just looking at this thread and am looking for some clarification, as i'm getting conflicting information. I am looking at potentially retiring outside of the UK and severing all ties with the UK. My buy to lets are within a limited company, as per Annie Qu's query. If i draw all dividends out of the company and close it, will the dividends taken be considered disregarded income and not taxed in the UK? Many thanks in advance.
Posted Mon, 02 Sep 2024 11:24:42 GMT by HMRC Admin 19 Response
Hi,

We cannot comment on future events as legislation and, or, plans may change. You can see current guidance here:

Tax on your UK income if you live abroad

Thank you.

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