Income Tax Act 2007 section 811

Limit on liability to income tax of non-UK residents

Section 811 caps the total income tax that a non-UK resident individual (or a non-UK resident company acting as trustee) can be required to pay for a tax year.

• The cap applies to non-UK resident individuals and non-UK resident companies acting as trustees, but not to non-UK resident companies generally
• Maximum liability equals Amount A (tax already deducted or treated as deducted from "disregarded income") plus Amount B (the tax that would arise on all other income, ignoring disregarded income and certain personal reliefs)
• The practical effect is that a non-UK resident cannot be asked to pay further tax on disregarded income beyond any tax already withheld at source or treated as paid on that income
• Personal reliefs available under residence provisions or double taxation agreements — including the personal allowance, blind person's allowance, married couple's or civil partner's allowance, and relief for trade union, police organisation, and life assurance premium payments — are excluded when calculating Amount B