3

From Residence, Domicile and Remittance Basis Manual 12010:

If during a year the individual starts to live or work abroad, or comes from abroad to live or work in the UK, the tax year will be split into 2 parts, if their circumstances meet specific criteria:

  • a UK part for which they will be charged to UK tax as a UK resident
  • an overseas part for which, for most purposes, the individual will be charged to UK tax as a non-UK resident.

Then, from Residence, Domicile and Remittance Basis Manual 12020:

An individual must be UK resident for a tax year under the SRT to meet the criteria for split year treatment for that year. They will not meet the split year criteria for a tax year for which they are non-UK resident under the SRT.

SRT stands for Statutory Residency Test and, as I previously expounded in this thread, I pass the test and I am indeed a tax resident for 2019-2020, even if only lived there from 6 April 2019 to 1 August 2019.

This is the part from Document 12020 that confuses me:

Split year treatment will not affect whether the individual is regarded as UK resident for the purposes of any double taxation agreement.

Isn't the whole point of the split-year treatment to affect the status of UK residency during the overseas part? That is, one is indeed a non-UK resident for that period of time?

Paul Razvan Berg
  • 1,307
  • 10
  • 20

1 Answers1

1

No, you're either a resident or a non-resident for the full year. Split year treatment just means you don't have to pay tax to the UK for the overseas part, but you're still considered UK tax resident for the whole year.

BTW, from your other post it seems you only lived in the UK for a few months. In this case, split year treatment would not apply since split year treatment requires you to be a resident for the following tax year (when moving to the UK) or the previous year (when leaving). See this HRMC publication.

tbm
  • 134
  • 2