Income Tax Act 2007 section 831

Foreign income of individuals in the United Kingdom for temporary purpose

Section 831 provides relief from UK income tax on foreign-source income for individuals who are in the United Kingdom only temporarily and do not stay for an extended period.

• An individual who comes to the UK without a view to establishing residence there, and who has not actually resided in the UK for 183 days or more in a tax year, may be treated as non-UK resident for certain foreign income purposes.
• Two rules apply: Rule 1 covers specific charges on foreign income (such as from overseas possessions or securities), and Rule 2 covers other foreign-source income — in both cases, the individual is treated as non-UK resident so the income escapes UK tax.
• Where the individual claims and obtains an exemption under section 651 of ITEPA 2003 (foreign earnings of individuals working abroad), the benefit of that exemption depends on a valid claim having been made and accepted by HMRC under section 647 of ITEPA.
• If the individual does actually reside in the UK for 183 days or more during a tax year, the temporary purpose relief is lost and the individual is charged to UK income tax on their foreign income for that year as if they were UK resident.

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