Hampton
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Split year treatment for domicile of choice
I am registering for Self Assessment for the first time, in order to pay tax on dividends in the US. I have lived in the UK for 6 years as a student, and my dividends have therefore been non-taxable in the UK under the terms of the UK-US tax treaty. However, I have adopted a UK domicile of choice, and therefore my understanding is that the dividends are taxable in the UK. When registering for Self Assessment, I must report the 'date started receiving taxable foreign income'. My rough deduction is that this should be the date of the first dividend received after adopting UK domicile, as adopting a domicile of choice would create split year treatment (maybe under case 4) for income that was previously untaxable. However, I have been unable to find clear HMRC guidance that this is correct.