Income Tax (Trading and Other Income) Act 2005 section 243

Extent of charge to tax

Section 243 defines the boundaries of the tax charge on post-cessation receipts, setting out when such receipts are taxable and the circumstances in which they are exempt.

• Post-cessation receipts are only taxable under this Chapter if they have not already been subject to income tax or corporation tax elsewhere, including where they have been included in the trade's profit calculations for any period.
• Receipts are exempt if they are received by or on behalf of a non-UK resident who is beneficially entitled to them and the income arises outside the United Kingdom.
• Receipts arising from a trade carried on wholly outside the United Kingdom are exempt, unless the trade involves dealing in or developing UK land; and a partner's share of foreign-source post-cessation income from a firm is exempt where the remittance basis applies to that partner.
• Where a UK resident individual has a split year, they are treated as non-UK resident for the overseas part of that year, potentially bringing them within the non-resident exemptions.