James Peyton Jones
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RE: New non-domicile rules and triggering of 4-year FIG period for tax-treaty dual residents
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New non-domicile rules and triggering of 4-year FIG period for tax-treaty dual residents
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?