P7. Individual ceasing to be UK resident

RESIDENCE TEST

INCOME TAX

Split-year

- Income and gains benefitting from split year treatment

Income

- Interest income (s.368(2)).

- Dividends (s.368(2)).

Legislation:

Cases:

HMRC manuals:

Commentary:

See also:

- Income and gains benefitting from split year treatment

Transfer of assets abroad

- Transfer to UK-resident individual who becomes non-resident as a relevant transfer

Legislation:

Cases:

HMRC manuals:

Commentary:

See also:

- Transfer to UK-resident individual who becomes non-resident as a relevant transfer

CAPITAL GAINS TAX

Section 87: matching benefits to gains

- Gains matched to benefits in a split year: gain accrues in UK resident part

- Where gains are treated as accruing to an individual in a split year, they are treated as accruing in the UK part of the tax year (s.87(2A)).

Legislation: TCGA s.87;

Cases:

HMRC manuals:

Commentary:

See also:

- Gains matched to benefits in a split year: gain accrues in UK resident part

INHERITANCE TAX

Long-term non-residence

- Charge on property becoming not relevant property when settlor becomes long-term non-resident

Confirm

Legislation:

Cases:

HMRC manuals: IHTM47023;

Commentary:

See also:

- Charge on property becoming not relevant property when settlor becomes long-term non-resident

P7. Individual ceasing to be UK resident

RESIDENCE TEST

​

INCOME TAX

​

Split-year

​

- Income and gains benefitting from split year treatment

Transfer of assets abroad

​

- Transfer to UK-resident individual who becomes non-resident as a relevant transfer

CAPITAL GAINS TAX

​

Section 87: matching benefits to gains

​

- Gains matched to benefits in a split year: gain accrues in UK resident part

INHERITANCE TAX

​

Long-term non-residence

​

- Charge on property becoming not relevant property when settlor becomes long-term non-resident