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Posted Wed, 08 Jan 2025 21:57:20 GMT by James Peyton Jones
The technical notes state "Qualifying individuals will not pay tax on FIG arising in the first 4 tax years after becoming UK tax resident". I am currently non-domiciled and non-UK-resident for the past 10 years. Suppose I move to the UK for 9 months and become dual resident UK and USA, but tax-treaty tie-breaker rules assign me to the USA for tax purposes: Will my dual residence status trigger the start of the 4-year FIG period, or does the tax treaty mean that I am not deemed "UK tax resident" (and therefore the FIG period is not triggered) despite my physical presence / dual-residence status?
Posted Thu, 23 Jan 2025 15:59:01 GMT by HMRC Admin 20 Response
Hi,
Guidance on the remittance changes is yet to be published.
Please have a look at Reforming the taxation of non-UK domiciled individuals.
Thank you.
Posted Thu, 23 Jan 2025 16:19:30 GMT by James Peyton Jones
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