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Posted Thu, 18 May 2023 10:52:28 GMT by
I am leaving the UK. The SRT considers me resident this tax year and the split year treatment applies. If a UK limited company that I own most of (so a close company) pays me a dividend during the overseas portion of the split year, is the dividend disregarded? Assume that I have been UK-resident for at least four of the seven years prior and also that I will not become UK-resident within 5 years. (In other words, the temporary non-residence rules are not an issue here.) In particular, I am trying to understand "The rule in ITA07/S811 only applies when an individual has been non-resident for the entire tax year. It does not apply, therefore, in the overseas part of a split year." in https://www.gov.uk/hmrc-internal-manuals/savings-and-investment-manual/saim1170 . So the rule does not apply, but what /does/ apply that led to the answers in https://community.hmrc.gov.uk/customerforums/sa/0a33e474-a4cb-ec11-bea1-00155d9c7f09 for the case of arriving in the UK?
Posted Wed, 24 May 2023 13:18:28 GMT by HMRC Admin 5
Hi,

If you qualify for split year then you only report any foreign income for the UK part of the year. You can find details here -

RDRM12000 - Residence: The SRT: Split year treatment: Contents

If you do not qualify then you will need to report all your foreign income to the UK,  please see Tax on foreign income  

The guidance at RDRM12150 at www.gov.uk will help you work out if split year treatment applies. 

Thank you
 

 

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