efficient
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Split year treatement of dividends when leaving the UK
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?